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BUS 419 CH 3 Key Terms

Jamie Plym Inglés 15 fichas

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  1. 1After-tax rate of returna taxpayer’s before-tax rate of return on an investment minus the taxes paid on the income from the investment. The formula for an after-tax rate of return that is taxed annually is the before-tax rate of return × (1 − marginal tax rate) [i.e., r = R × (1 − t)]. A taxpayer’s after-tax rate of return on an investment held for more than one tax period is r = (FV/I)1/n − 1, where r is the after-tax rate of return, FV is the after-tax future value of the investment, I is the ­original investment amount, and n is the number of periods the ­investment is held.
  2. 2Arm’s-length transactionstransactions among unrelated taxpayers, where each transacting party negotiates for his or her own benefit.
  3. 3Assignment of income doctrinethe judicial doctrine holding that earned income is taxed to the taxpayer providing the service, and that income from property is taxed to the individual who owns the property when the income accrues.
  4. 4Before-tax rate of returna taxpayer’s rate of return on an investment before paying taxes on the income from the investment.
  5. 5Business purpose doctrinethe judicial doctrine that allows the IRS to challenge and disallow business expenses for transactions with no underlying business motivation.
  6. 6Constructive receipt doctrinethe judicial doctrine that provides that a taxpayer must recognize income when it is actually or constructively received. Constructive receipt is deemed to have occurred if the income has been credited to the taxpayer’s account or if the income is unconditionally available to the taxpayer, the taxpayer is aware of the income’s availability, and there are no restrictions on the taxpayer’s control over the income.
  7. 7Discount factorthe factor based on the taxpayer’s rate of return that is used to determine the present value of future cash inflows (e.g., tax ­savings) and outflows (taxes paid).
  8. 8Economic substance doctrinejudicially based doctrine that requires transactions to meaningfully change a taxpayer’s economic position and have a substantial purpose (apart from a federal income tax purpose) in order for a ­taxpayer to obtain tax benefits.
  9. 9Implicit taxesindirect taxes that result from a tax advantage the ­government grants to certain transactions to satisfy social, economic, or other objectives. They are defined as the reduced before-tax return that a tax-favored asset produces because of its tax-advantaged status.
  10. 10Present valuethe concept that $1 today is worth more than $1 in the future. For example, assuming an investor can earn a 5 percent after-tax return, $1 invested today should be worth $1.05 in one year. Hence, $1 today is equivalent to $1.05 in one year.
  11. 11Related-party transactionfinancial activities among family members, among owners and their businesses, or among businesses owned by the same owners.
  12. 12Step-transaction doctrinejudicial doctrine that allows the IRS to ­collapse a series of related transactions into one transaction to determine the tax consequences of the transaction.
  13. 13Substance-over-form doctrinejudicial doctrine that allows the IRS to consider the transaction’s substance regardless of its form and, where ­appropriate, reclassify the transaction according to its substance.
  14. 14Tax avoidancethe legal act of arranging one’s transactions or affairs to reduce taxes paid.
  15. 15Tax evasionthe willful attempt to defraud the government (i.e., by not paying taxes legally owed). Tax evasion falls outside the confines of ­legal tax avoidance.

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Bu 419 ch 3 key terms
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Jamie Plym
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