Saturday, December 21, 2019

Annotated Bibliography On Corporate Reorganization

Tax Research Memorandum Date: November 16, 2014 To: Tax Files From: Jonathan Ruhi Subject: Availability of Corporate Reorganization Summary of Facts Chris and Sue are 50 percent shareholders in BackBone personal service corporation. Backbone provides chiropractic services in four separate offices, in four small towns: Troy, Union, Vista and Willow. Chris is the main chiropractor in the Troy office, and Sue heads up the Vista office. Charlie, the main chiropractor in the Willow office, does not see eye-to-eye with Chris and Sue on management styles. Charlie is highly competent and well-liked by patients and therefore indispensable in the eyes of Chris and Sue. Chris and Sue may be willing to give Charlie control of the Willow office,†¦show more content†¦In addition, Chris and Sue will not have to worry about any loss of profits since the profits of the new subsidiary corporation will flow through to the BackBone personal service corporation. Issue and Conclusion 2 How should the corporate reorganization be structured? The corporate reorganization should be structured as a divisive â€Å"D† reorganization and the restructuring process should conform to section 355 of the tax law in order to minimize the tax consequences of the reorganization. Law and Analysis 2 Section 368(a)(1) of the tax code provides several options for corporate reorganizations. Section 368(a)(1)(d), also known as a â€Å"divisive D reorganization†, is the best choice for this particular situation. In a divisive â€Å"D† reorganization, the controlling corporation (in this case, BackBone) will distribute assets (the Willow office) to a newly formed subsidiary corporation, in exchange for the stock of the new subsidiary corporation, in a transaction that qualifies under section 355 (Sec. 368(a)(1)(d)). After the transaction is complete, the Willow office will be its own corporation which is wholly (or at least mostly) owned by BackBone. BackBone will also still own and control the Troy, Union and Vista offices after the reorganization. Issue and Conclusion 3 What will be the tax consequences of the reorganization? Section 355 of the tax code will drastically reduce, or even completely eliminate, any tax liability caused by

Friday, December 13, 2019

Alcohol Abuse in Russia Free Essays

string(65) " prices and the rates of violent deaths increased substantially\." Joe Bloe Professor I. B Smart BS 131 December XX, 2008 Alcohol Abuse in Russia Family Issues Russians drink more alcohol than any other nation in the world. (Halpin, 2007, p1) The Times of London reports that Russians are currently going on an alcoholic binge even by Russian standards. We will write a custom essay sample on Alcohol Abuse in Russia or any similar topic only for you Order Now According to the country’s chief public health officer, Gennadi Onishenko, Russians are drinking nearly three times as much as they did sixteen years ago. Onishenko’s study was promulgated by the Russian equivalent of the consumer protection agency and it reported that at least 2. million people in Russia were alcoholics. The average Russian consumed 15 litres (26 pints) of pure alcohol per annum, up from 5. 4 litres in 1990, and this phenomena is blamed for a rising rate of mortality among men. This compares to 8. 4 litres for people in the United States and 7. 6 litres in Japan. (Halpin, 2007 p 1) Violent crime and alcohol consumption have increased throughout the Russian federation since the fall of the Soviet Union. This has shown harmful consequences for families and communities, as heavy alcohol drinking is closely associated with violent behavior in Russia.The correlation between heavy drinking and violence is a complicated mixture of physiological, psychological, situational, social and cultural elements. Whenever measures to control alcohol production and consumption have been introduced, reduced violence has occurred in Russia and elsewhere. (WHO, 2006) Violence is a family’s worst enemy and may include physical and sexual assaults, mental or emotional abuse and neglect. It may also be categorized into interpersonal violence, child maltreatment or neglect, intimate partner violence within a relationship, sexual violence, abuse of the elderly or self-directed violence including suicide. WHO, 2006) There is ample evidence to support the relationship between heavy drinking and violence. In Russia, alcohol has been involved in three-quarters of homicide arrests. Families often bear the brunt of the violence that emanates from heavy drinking. In the Central Black-Earth Region of Russia, a study showed that 77% of violent crimes against family members involved drinking with 35% of these drinkers bingeing every day. Among male perpetrators of spousal homicide, 60–75% of offenders had been drinking before the incident. (WHO, 2006)Alcohol abuse affects physical and cognitive functioning resulting in reduced self-control and the ability to process incoming information. This makes drinkers more apt to resort to violence to resolve conflicts. (Rand Corp. , 2002) Heavy drinking can impair parents’ responsibilities toward themselves and their children. Drinking also reduces the amount of time and money spent on their children, often neglecting the children’s basic needs. Alcohol abuse by either the parent or the child increases the child’s vulnerability to sexual abuse.Sometimes children are made to drink alcohol to facilitate sexual acts or involve them in child pornography. (WHO, 2006) Alcohol abuse during pregnancy can result in children being born with fetal alcohol syndrome as well as health issues for the mother. Excessive drinking in a relationship can create problems with finances, childcare, infidelity or other stressors leading to potentially violent situations. (WHO, 2006) Health Issues Russians are suffering from a problem with demographic retention and a declining population base.Alcoholism is a leading cause in rising Russian mortality rates, particularly among males. Alcohol contributes to premature deaths involving accidents, injuries and violence particularly among males. Male mortality rates fell sharply during Gorbachev’s anti-alcohol campaign of 1984 to 1987. This effort reduced state alcohol production, raised prices for liquor, mandated alcoholic treatments where needed and cracked down on homemade liquor. The program was highly unpopular and abandoned, after which both consumption of alcohol and mortality rates for males increased dramatically once again. Rand Corp. , 2002) Russia’s population has dropped from 145 million in 2002 to 140,702,000 in July of 2008. The birth rate is slightly higher at 11. 3 births per 1,000; up from 9. 1 per 1,00 in 2002. Male life expectancy is only 59 years and for females it is 73 years. (Fitzgerald, 2003, CIA 2008) Statistics for children are not encouraging. In 2003, the number of healthy children in Russia dropped from 45. 5 percent to 33. 9 percent over ten years, and the number of disabled children doubled, according to the epidemiology section of the Health Ministry.According to information gathered form the 2002 census, one third of Russian children are born out of wedlock. (Fitzgerald, 2003) The Russian Ministry of Health did not blame alcoholic parents for substandard health environments or the usual culprits of drug abuse, or smoking and eating junk food but blamed an increase in the school workload and less time for outdoor exercise. The Ministry claimed that an incredible 75% of children were said to have hypertension and related problems in the 2003 analysis of Russian health. (Fitzgerald, 2003)Beer is regarded in many areas as if it were soda pop. Children as young as 13 routinely drink beer in public in some areas and the national legal drinking age is currently 18 years. Vodka has traditionally been available nearly everywhere to nearly everybody in Russia and children have no problem finding it. As in America and elsewhere, heavy alcohol consumption in Russia impedes a family’s well being in a host of problematic ways. And Russians drink more alcohol per capita than any other national population in the world. (Halpin, 2007)Gorbachev’s attempt to limit alcohol abuse In 1985 President Gorbachev, who was then president of the USSR, began a campaign to limit alcohol abuse by raising the legal drinking age to 21 years and imposing tough legal sanctions on home production of alcohol. (Today, the drinking age is 18 years. ) During the period of 1984 through 1987 when the campaign was running, state sales of alcohol decreased by 61%. Statistically speaking, the effort was successful in that total violent deaths dropped 33% and alcohol-related violent deaths dropped by 51%. The program was not popular with the public, however, and was abandoned in 1987. By 1992, market reforms for alcohol were instituted that liberalized trade and dropped prices and the rates of violent deaths increased substantially. You read "Alcohol Abuse in Russia" in category "Papers" (WHO, 2006) These rising figures are subject to interpretation because this was the era of perestroika in Russia and increases in violent deaths cannot be solely attributed to increases in alcohol availability and consumption. The temporal correlations between the crackdown on alcohol and the drops in violence indicate that they are interconnected.Perestroika and glasnost were introduced to Russian society in response to President Gorbachev’s initiatives toward political reform and moral recovery. A cornerstone of his plan was a reduction in drinking which he saw not only as a health problem but a cause of economic inefficiency. (McKee, 1999) He adopted a heavy-handed approach to limiting alcoh ol production, distribution and use. All state agencies were ordered to develop departmental strategies to cut down alcohol consumption. Alcohol was banned at official functions and party officials who drank heavily were dismissed from their jobs.Liquor outlets were dramatically reduced and the media changed its attitude to one of intolerance for alcohol and organizations like the All-Union Voluntary Society for the Struggle for Sobriety sprang up. This association claimed 12 million members one year after organizing. (McKee, 1999) Within a few years, as the Soviet Union was collapsing, the campaign faltered and was eventually replaced by a rapid rise in consumption, driven by widespread illicit production of homemade alcohol on a massive, national scale. Economic IssuesRussia’s stock markets have lost about 70 percent of their value since peaks in May, and workers have been hard hit by lay-offs and wage arrears. The tepid global economy has left Russians hurting and they, like most of the world, have had to cut back on expenses. The result is less state-sanctioned vodka being sold and an increase in homemade spirits. Research by the National Alcohol Association showed that deaths from alcohol poisoning increased to 1,458 in September, presumably the result of Russians drinking dangerous substitutes for vodka as a cheaper way to get drunk. (Shuster, 2008)During Gorbachev’s anti-alcohol campaign, the production of samogon (homemade spirits) had become a large-scale industry that provided cheap alcohol to Russians while depriving the state of tax revenue. When restrictions were eased in 1988, alcohol consumption quickly exceeded the pre-1985 level. A Russian study done in 1995 revealed that regular drunkenness affected between 25 and 65 percent of blue-collar workers and 21 percent of white-collar workers, particularly in rural areas. (Coutsoukis, 2005) Unemployed workers are particularly vulnerable to alcohol abuse problems.Being available in most places, day or night and being historically cheap peopl e without occupations tend to drink more often and heavier. When vodka is unavailable or too expensive, they will often resort to dangerous substitutes. In 1994, the number of people who died of alcohol poisoning rose to about 53,000, a major increase from 36,000 in 1991. These are typically the result of drinking homemade alcohol substitutes. Bootlegging had become a widespread criminal activity by the mid 1990s. (Coutsoukis, 2005) Legal vodka is big business in Russia.The word â€Å"vodka† means â€Å"little water† in Russian, a term of endearment. (Tartakovsky, 2006) The brand â€Å"Stolichnaya† sells $2 billion a year worldwide and was privatized in 1992. Soyuzplodimport, or SPI, has the exclusive rights to export Stolichnaya, which vodka lovers in the U. S. fondly refer to as â€Å"Stoli. † Some 50% of the company’s export turnover comes from the United States, thanks mostly to its strategic alliance with Allied-Domecq for U. S. distribution rights. (Shuster, 2008) Alcohol and workers The Russian workplace has always been a place where vodka contributed to the socializing rituals. Before the Bolshevik Revolution the Russian tradition of prival’naia, a welcoming ceremony for new workers that included snacks and vodka. It was a socializing event where the new workers would become acquainted with their fellow workers. The new workers were expected to provide the snacks and vodka for the veterans in exchange for training in the new job. (Andreasen, 2006) The Revolution changed the way workers were hired. Prior to this era, workers were usually hired on the recommendation of an acquaintance and the ceremony of prival’naia was part of the payback for getting the job.With the implementation of the communist trade unions, the hiring became an impersonal process and there was no payback necessary and it eliminated the worker’s obligation to train new employees. These changes brought about the practical end to prival’naia, although some workers and organizations still clung to the old tradition where they could get away with it. (Andreasen, 2006) Russian worker culture has always included vodka. The working class sees vodka as an essential element for surviving their brutal winters and poor economy.It is an escape that causes apathy among the work force and contributes to poor health and accidents that make Russia’s work force less productive and more costly. Productivity in Russia has always been known to suffer because of heavy drinking. That belief is one of the motivators behind Gorbachev’s plan to reduce drinking in the 1980s. It is difficult to gauge the true impact of worker drinking and productivity because the Russian economy is still in a state of flux as it transfers from a state-controlled, centralized economy to free-markets. It is inappropriate to make comparisons about worker utput and drinking since the two economies measure productivity in myriad different ways. (Kryzanek, 2004) Many Soviet patriots and party leaders recognized the need to curb alcohol to increase worker productivity.Pokhlebkin was one of these patriotic historians who published his extensive research in a book called â€Å"A History of Vodka† he included a chapter depicting what he determined to be Russia’s descent into rampant alcoholism. Drunkenness, he asserted, is incompatible with socialist principles in that it undermines worker morale and curtails industrial productivity. Tartakovsky, 2006) Russian workers have become complacent after seventy years of communism. Entire generations have grown up shirking work because private initiatives were always discouraged and sometimes even dangerous. Wage inversion led to high pay for lowliest work while job dissatisfaction created moonlighting and demoralized workers moved from job to job. Alcohol has always exacerbated this complacency and lack of motivation. (Kryzanek, 2004) Heavy drinking has a deeply rooted history in Russian culture and life.The problem seems so ingrained in their society that it would be impossible to completely eliminate drinking from the society. This heavy drinking behavior is exhibited in other northern cultures like the Finish or Polish societies without such devastating consequences. In Russia, however, there is historical evidence to suggest that the country’s governments from the Czars to the Soviets have helped to create this culture. (McKee, 1999) There are also several sub-cultures of the drinking population in Russia because of geographic, gender and socio-economic variations, making it difficult to generalize the problem.There are even some people among these groups who actually abstain or drink in moderation. The state itself has contributed to the drinking problem throughout the country’s history by producing and distributing cheap vodka in the name of tradition and profit. It should be feasible for the government to take some kind of proactive measures to stop its population from killing themselves with even-more toxic substitutes for a toxic product. Apparently, it will take many generations of sober Russians to change the high-profile role alcohol plays in so many national traditions.The Russian people have gone through many changes throughout the ages. Hopefully, their resilience will help them change their love of vodka and allow them to become socially conscious drinkers. That’s a tradition easily passed on. How to cite Alcohol Abuse in Russia, Papers

Thursday, December 5, 2019

Ralph Ellisons Invisible Man free essay sample

An analysis of the novel Invisible Man by Ralph Ellison. This paper examines Ralph Ellisons work `Invisible Man.` The author writes it is a book about race in America and, sadly enough, few of the problems it chronicles have disappeared even now. The paper describes the books compelling portrait of this New York community in the decade and a half after World War I as a place of intellectual fervor and intoxicating creativity. It is a commonplace habit of humans, to rely on the visual aspects of humanity as a means of learning who we are. It is also, as Ralph Ellison argued in his 1952 novel Invisible Man, a very dangerous habit. The novel chronicles the travels of its narrator, a young, nameless black man, as he moves through a Dantean series of circles of racism, intolerance and cultural blindness. Despite the harshness with which he is met, he continues to search for a cultural and social context in which he can come to know himself. We will write a custom essay sample on Ralph Ellisons Invisible Man or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page He searches throughout the novel for a way in which he can end his own invisibility; he struggles to be a real man rather than a prism or a mirror or a ghost.

Thursday, November 28, 2019

The Bottom of Space free essay sample

†¦The blistering cold pierced my skin as a sword pierces flesh. Despite the amount of protective gear that I was wearing, I could not lock the cold out. Never in my wildest dreams did I imagine that I would ever experience so much torture. I continued to climb, knowing all along that the climb might be my undoing. The storm was worsening. A blanket of snow smothered everything in white. Without the 80 MPH wind, it would have been an easier assent. However, the wind was there, and it turned the snow into a weapon, billions of needles that penetrated my gear and attempted to destroy me. Steve was no longer in sight; the only indication he was still alive was the tension on the ten foot rope that united us. I estimated that we were about 27,000 feet high with still another 2,000 feet to go. This is the stage of the climb that we have trained our lungs for, but never did we imagine that our lungs would deal with this paucity of oxygen. We will write a custom essay sample on The Bottom of Space or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page When we hit 28,000 feet, the storm relented. The sun punched through the clouds, slowly warming our frost bitten faces. I suddenly came to the realization that we climbed higher than the clouds could dream of reaching. Steve finally became visible in front of me, and looked back at me with a smile. â€Å"One-thousand feet to go,† I yelled to him. His smile grew brighter and he turned, looking forward once again. No words needed to be exchanged, for the message was evident to both of us. In another thousand feet, we were going to accomplish the goal that we have dreamed since we first began climbing. We entered a state of Nirvana, a level of excitement that only people who climbed this high could understand. After another hour of walking, we reached our goal, the summit of Mount Everest. For the first time in three months since arriving at Base Camp One, we stopped, awe-stricken by the sight before us. The bright blue sky above us appeared as a blanket for the world, surrounding it and keeping it warm. The sun was completely visible at 29,029 feet above sea level, and was high above us as a trophy of our accomplishment. This was a trophy that few men in history have held. Steve turned to me and we embraced each other in our excitement. â€Å"We did it!† Steve proc laimed to me, â€Å"We reached the top of the world!† That phrase took a great toll on me. I did not see this climb as the pinnacle of our lives, but as only ticking off one of many on a long list of future accomplishments. It is at the top of this mountain that a person realizes that there is a substantial amount still to accomplish. For some, it is to continue climbing. For others, it is to settle down and have the peaceful life we climbers have always dreamed. There was a fork at the summit of Mount Everest with a sign in the middle. In one direction, the sign reads the top of the world. In the other direction, the sign reads the bottom of the universe. Steve was taking the road that read â€Å"the top of the world†, and I was taking the road that read the â€Å"bottom of the universe†. â€Å"Are you ready to head back down?† Steve asked as he broke my train of thought, â€Å"It has been a half hour already, and we want to make it back to Camp IV befo re the afternoon weather sets in.† â€Å"Alright, let’s go,† I replied. We made it down to 27,500 feet without difficulty. However, we had no choice but to walk right into the storm we faced during our assent. The afternoon weather intensified the storm exponentially. We were in a fight for our lives once again†¦

Sunday, November 24, 2019

Zion essays

Zion essays Theodor Herzl was certainly not the first Jew to dream of Zion, but he nevertheless put the wheels in motion (Zionism 1). Zionism is the name given to the political and ideological creation of a Jewish national state. The rise of the Zionist movement in the late 19th century culminated in the creation of this state in Palestine in 1948. Herzl was born of well to do middle-class parents. He first studied in a scientific secondary school, but to escape from its anti-Semitic atmosphere he transferred in 1875 to a school where most of the students were Jews. In 1878 the family moved from Budapest to Vienna, where he entered the University of Vienna to study law. He received his license to practice law in 1884 but chose to devote himself to literature. Remaining in Vienna, he became o correspondent for Neue Freie Presse (New Free Press), the liberal magazine of the bourgeoisie. In 1889 he married Julie Naschauer, daughter of a wealthy Jewish businessman in Vienna. The marriage was unhappy, although three children were born to it. Herzl had a strong attachment to his mother, who was unable to get along with his wife. These difficulties were increased by the political activities of his later years, in which his wife took little interest. These political activities culminated in 1896, when Herzl published Der Judenstaat, an informational pamphlet in which he proposed that the Jewish question was a political question to be settled by a world council of nations. Although the liberal magazine he worked for tried to prevent the publication of Der Judenstaat and never so much as mentioned it in its columns, Herzl would not be deterred. He gathered a small coterie and set out to convene the First Zionist Congress that same year. Being the first political movement to unify the diverse proto-Zionists, five delegates among 200 men and perhaps as many as 10 women convened the First ...

Thursday, November 21, 2019

Advantages and Disadvantages of Assistive Technologies for students Research Paper

Advantages and Disadvantages of Assistive Technologies for students with Learning disabilities - Research Paper Example In essence, reading, listening, speech, algebra, and reasoning are the prime areas in which learning disabilities tend to affect on children. Moreover, students with learning disabilities or disorders have a higher potential of succeeding as long as the teaching technique used on them is different from that used on average kids. Ideally, there is no medical symptom that may show that a child has learning disabilities, but this does not mean that the condition is non existent. Learning disabilities are not curable, but the use of certain application tools may be helpful in ensuring that a child with this disability works out the learning challenges that they may have. On the contrary, these tools are technology aides that assist a child to organize, write, spell among a list of other daily activities with ease and they may be complex or common devices. With this, this essay will delve into the advantages and disadvantages of using assistive technologies for students with learning disa bilities. Features of assistive technologies for learning Ideally, assistive technology is a term that describes the family of rehabilitative, aiding, and adaptive technology applying devices made for people living with learning disabilities. ... The advancement in technology has led to the development of equipments that have proved effective for the disabled with any form of shortcomings. For those with learning disabilities, assistive technology products include screen readers and voice recognition devices, which mainly target those with indisputable communication challenges, learning, hearing, and arithmetic needs. Ideally, people have different ways of accessing and communicating in which assistive technologies can be effective using joysticks, touch screens, software, and switches that may be essential for them to accomplish tasks. These tools act as aides to students with learning disabilities through these devices in order for them to keep up with the other normal children. Advantages of Assistive Technologies for students with Learning disabilities As stated above, Assistive Technology is any equipment that when used improves, maintains, or increases the performance capabilities for people with disabilities. The first advantage of using Assistive Technology is that it supports an individual’s strengths hence suppressing the effects that disabilities may bring by. The other advantage is that these technologies give individuals with disabilities alternative ways of performing the required tasks using these technologies, which makes the task execution to be maneuverable. For instance, people that have unreadable handwriting may use word processors to help them improve on this skill, which in turn helps them produce documents are readable and appealing to their eyes of a reader. Other than writing, Assistive Technology (AT) can also be helpful in building their self-esteem as it gives an avenue for the improvement on their written expressions such as spelling and