Free Essay

Avoiding Gain While Transferring Property and Liability to a Controlled Corporation

In: Business and Management

Submitted By joehourigan
Words 1737
Pages 7
qwertyuiopasdfghjklzxcvbnmqwertyui opasdfghjklzxcvbnmqwertyuiopasdfgh jklzxcvbnmqwertyuiopasdfghjklzxcvb nmqwertyuiopasdfghjklzxcvbnmqwer Avoiding Gain While Transferring Property and Liability to a Controlled tyuiopasdfghjklzxcvbnmqwertyuiopas Corporation dfghjklzxcvbnmqwertyuiopasdfghjklzx cvbnmqwertyuiopasdfghjklzxcvbnmq wertyuiopasdfghjklzxcvbnmqwertyuio pasdfghjklzxcvbnmqwertyuiopasdfghj klzxcvbnmqwertyuiopasdfghjklzxcvbn mqwertyuiopasdfghjklzxcvbnmqwerty uiopasdfghjklzxcvbnmqwertyuiopasdf ghjklzxcvbnmqwertyuiopasdfghjklzxc vbnmqwertyuiopasdfghjklzxcvbnmrty uiopasdfghjklzxcvbnmqwertyuiopasdf ghjklzxcvbnmqwertyuiopasdfghjklzxc

Avoiding Gain While Transferring Property and Liability to a Controlled Corporation
Summary Internal Revenue Code (IRC) Section 357(a)1 provides that when property is transferred to a controlled corporation in a transaction that qualifies under Section 351 2, and the property transferred has a liability attached to it, the liability assumed by the corporation is not a recognized gain to the transferor – it instead reduces the adjusted basis of the transferred property. If the liability assumed in the transfer exceeds the property adjusted basis – Section 357(c) provides that the excess liability is a recognized gain to the transferor. The prospect that business persons who incorporate their businesses, and in so doing might incur sizable income taxes due to transferred property liabilities exceeding adjusted basis, has no doubt led many to consider ways to increase the adjusted basis of the property transferred to avoid the tax. I suspect that research will uncover IRS Revenue Rulings, court cases, articles, etc., that will detail attempts by property transferors to avoid the gain recognition due because of Section 357(c) in Section 351 transactions. That will be the focus of this paper.

Research Lipton and Bender3 describe situations where taxpayers have attempted to avoid recognition of gain on property transfers due to the application of IRC 357(c). Stuffing transactions are those where taxpayers attempt to take advantage of the fact that the gain recognized by IRC 357(c) is applied to the liability in excess of the aggregate adjusted basis of all the property transferred – not just the basis of the property items that have liabilities. Taxpayers will stuff additional property items into the transfer to raise the aggregate basis up to or in excess of the liabilities transferred.

2

They describe that stuffing transactions can be legitimate. As long as the additional property items transferred have valid business uses, the stuffing transaction will be legal and no gain will be recognized. They point out too that some stuffing transactions are deemed abusive by the Internal Revenue Service (IRS), such as when a taxpayer conducts a transaction that creates assets with high tax basis and low fair market value and transfers the assets to the corporation without gain recognition. Step approach transactions are another method that taxpayers use to attempt to avoid IRC 357(c). The common way to do this is the taxpayer borrows cash from a third party and adds the cash to the property basis to meet or exceed the liabilities assumed by the corporation. The corporation then uses the cash to purchase the taxpayer’s note from the third party. The IRS will likely collapse these steps and claim the taxpayer has contributed his own note to the corporation just to avoid a taxable gain. The note will be deemed to have zero basis because it did not cost the taxpayer anything. A third method used to circumvent IRC 357(c) is when taxpayers make a capital contribution to the corporation in the amount of the difference of the property adjusted basis and the assumed liabilities. If the capital contributed is cash or a legitimate third party note, then there is no problem and IRC 357(c) can be avoided. If the taxpayer contributes his own promissory note to the corporation, the IRS will deem the note to have a zero basis and cannot be used to offset the liabilities. Taxpayers have attempted this third method many times and it has led to several interesting and varied rulings and court cases. Revenue Ruling 68-6294 is a concise response from the IRS to a taxpayer who transferred all of his assets in a sole proprietorship to a new corporation in a transfer that qualified under IRC 351(a). The liabilities on the property transferred exceeded the adjusted basis. The

3

taxpayer attempted to offset the excess value of the liabilities over the assets value by transferring a promissory note for the difference. The IRS ruled that IRC 10125 provides that the basis of property is its cost. Since the promissory note cost the taxpayer nothing, it did not increase the basis of the assets transferred. In Velma W. Alderman v. Commisioner6, the Tax Court upheld the IRS ruling that the Aldermans owed tax on excess liability in an IRC 351 transfer. The Aldermans owned a sole proprietorship lumber trucking business in Oregon, and in 1963 they incorporated their business. The assets: trucks and trailers, had adjusted basis of $62,782.20. The liabilities assumed by Alderman Corporation were: accounts payable, $24,420.14, and loans on the truck and trailers, $47,591.65. The liabilities exceeded the asset adjusted basis by $9229.59. The Aldermans contributed a promissory note of $10,229.59 to the corporation, creating a capital stock account of $1,000. The Tax Court agreed with the IRS that the promissory note had zero basis and that the taxable income for the Aldermans for 1963 should be increased by $9,229.59. In two more recent court decisions covering cases similar to Alderman, Courts of Appeals overruled the Tax Court. In 1977, Sol and Judith Lessinger7 incorporated their sole proprietorship, Universal Screw and Bolt Co. in a Section 351 transfer. The corporation assumed liabilities of $1.1 million and the liabilities exceeded the asset adjusted basis by $255,000. The Lessingers were oblivious to the tax they owed on the $255,000 of excess liability and carried the debt on their books. In 1981, at the request of one of the Lessinger’s creditors, Mr. Lessinger issued a promissory note to the corporation for $255,000. The IRS ruled that the Lessingers owed tax on the $255,000 of excess liability from the incorporation of their business in 1977. The Tax Court agreed. The Lessingers appealed their case to the U. S. Court of Appeals, Second Circuit which reversed the Tax Court. The Second Circuit agreed with the

4

Tax Court that the Lessingers had no basis in the note. But it found that the corporation should have a basis in the note. The court recognized that its ruling ran counter to IRC 362 8 which provides a carryover basis to transferred property. The court supported its decision by finding that the purpose of IRC 362 is to prevent an increased basis of property transferred to a corporation without gain recognition. The court found this lower basis of property allows for more depreciation deductions. But depreciation does not apply to a promissory note contribution. So the Second Circuit allowed the Lessingers to avoid paying tax on the excess liability of $255,000. In a case similar to Lessinger, Daniel and Judith Peracchi9 incorporated their life insurance businesses into NAC Corporation in 1989. The Peracchis contributed over $3 million of property with basis of $981,406 and liabilities of $1,548,212. The liabilities exceeded the property basis by $566,806. To add additional capital to NAC, the Peracchis also contributed an unsecured promissory note in the amount of $1.06 million. The IRS ruled that the Peracchis had a recognized gain of $566,806. The Tax Court upheld the IRS ruling. The Tax Court stated it was unlikely that the Peracchi’s would ever pay off the note, that its only purpose was to avoid taxation. The Peracchis appealed their case to the U. S. Court of Appeals, Ninth Circuit which reversed the Tax Court. The Ninth Circuit agreed that the Peracchi’s note had no basis and there was no guarantee that the note ever would be collected, and therefore may never cost the Peracchis anything. But the court evaluated other circumstances in which the note might be collected without the Peracchi’s consent. The court found three situations where the Peracchi’s could be caused to repay the note. NAC Corporation could enforce the note. This was not likely given that the Peracchi’s controlled NAC. Second, NAC could sell the note to a third party and the third party could enforce the note repayment.
5

Third, bankruptcy could force the Peracchis to have to pay the note. The court found that because bankruptcy was a real possibility for NAC, and the note would still be present if NAC went bankrupt, the note had actual economic value and should have a basis equal to its face value to both the Peracchi’s and NAC Corporation. Conclusions The examples of Alderman and Peracchi where the Tax Court ruled against the taxpayers because notes transferred had no basis that were subsequently overturned by the Courts of Appeals appear to be aberrations. One comment 10 stated that the Ninth Circuit, which ruled in Peracchi, pointed out that IRS Revenue Rulings, such as Rev. Rul. 68-629, are not entitled to as much deference as are regulations. The Ninth Circuit felt that Rev. Rul. 68-629 offered little in support of its position that promissory notes had no basis. But it is certainly not clear how much basis a promissory note would have if Peracchi was not in financial trouble and the note was not transferable. No relevant IRS regulations governing IRC 357(c) have been published subsequent to the Ninth Circuit’s ruling in Peracchi. I believe it would be wise for taxpayers who incorporate their businesses to find ways to avoid the tax because of IRC 357(c) that are currently accepted by the IRS, and not count on Courts of Appeals to find novel ways to rule in their favor and overturn the IRS and the Tax Court.

6

References 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Internal Revenue Code Section 357 – Assumption of Liability Internal Revenue Code Section 351 – Transfer to Corporation Controlled by Transferor Lipton, R. M., and J. E. Bender. 1999. Peracchi and Making Something Out of Nothing, or Does Debt Have a Zero Basis to its Maker… Taxes – The Tax Magazine March: 1-19. Revenue Ruling 68-629, 1968-2 CB 154 January 1, 1968 – Section 357. - Assumption of Liability Internal Revenue Code Section 1012 – Basis of Property-Cost V. W. Alderman, 55 T.C. 662, Dec. 30, 611 (1971) S. Lessinger, CA-2 89-1 USTC paragraph 9254, 872 F2d 519 Internal Revenue Code Section 362 – Basis to Corporations D. J. Peracchi, CA-9, 98-1 USTC paragraph 50,374, 143 F3d 487 CCH Tax Research Consultant, CCORP: 3,106.10, Assumed Liabilities in Excess of Basis

7

Similar Documents

Free Essay

The Impact of Transfer Pricing on Corporate Disclosues

...The Impact of Transfer Pricing on Corporate Disclosures Written By: Roger Hsueh Aiming to plug tax collection leaks, impose reasonable tax burdens and bring Taiwan in line with the international trend, toward the end of 2004 the Ministry of Finance issued and put into effect "Income Tax Audit Standards for Transfer Pricing Inconsistent with Arm’s Length Transactions". Following the implementation of the transfer pricing audit standards, not only will the taxation authorities be able to investigate back five years to see if corporate income taxes were consistent with “arm’s length” transactions; henceforth the burden of proof will have shifted from the National Tax Administration to corporations. Corporations will have to furnish evidence on their own behalf to prove their transactions are consistent with arm’s length ones, furnishing the relevant documents. As a result of this, thousands of entities - affiliated companies, parts of corporate groups, foreign businesses in Taiwan, and factories set up in Mainland China - face heavy tax risk on their “related party transactions”. And for public companies, because of their larger scale of operations and the ease of obtaining their regularly issued financial statements, the disclosures in public company financial statements prescribed by the transfer pricing audit standards will have a major impact. As provided in “Guidelines Governing the Preparation of Financial Reports by Securities Issuers”, when a public company......

Words: 3479 - Pages: 14

Free Essay

Chapter C: 2 Answers

...the Corporation Discussion Questions C:2-1 A new business can be conducted as a sole proprietorship, partnership, C corporation, S corporation, LLC, or LLP. Each form has tax and nontax advantages and disadvantages. See pages C:2-2 through C:2-7 for a listing of the tax advantages and disadvantages of each form. A comparison of the C corporation, S corporation, and partnership alternative business forms appears in Appendix F. pp. C:2-2 through C:2-8. C:2-2 Alice and Bill should consider forming a corporation and making an S corporation election. An S corporation election will permit the losses incurred during the first few years to be passed through to Alice and Bill and be used to offset income from other sources. The corporate form allows them limited liability. As an alternative to incorporating, Alice and Bill might consider a limited liability company that is taxed as a partnership. pp. C:2-6 through C:2-8. C:2-3 The only default tax classification for the LLC is a partnership. Because the LLC has two owners, it cannot be taxed as a sole proprietorship. The entity can elect to be taxed as a C corporation or an S corporation. If the entity makes such an election, Sec. 351 applies to the deemed corporate formation. The entity would have to make a separate election to be treated as an S corporation. pp. C:2-8 and C:2-9. C:2-4 The default tax classification for White Corporation is a C corporation. White can elect to be taxed as an S corporation......

Words: 14473 - Pages: 58

Premium Essay

Lifting the Veil

...incorporation of a projected or existing enterprise. Under s15(1) of the Companies Act 2006, companies which are registered become incorporated and separate legal persons on registration. As a consequence of the existence of a distinct legal entity, a company has the capacity to be a party to a contract, sue or being sued, commit a crime, be the victim of a crime, hold property, and rationally, thus, make profits and losses that are its own rather than those of the shareholders of the company. The Principle of Separate Legal Personality The importance of the corporate personality which was created by statute in the first half of the nineteenth century was not fully appreciated until the well-known case of Salomon. This case firmly established the operation of the concept of the separate legal personality of a company under the Companies Act of 1862 and this principle is still existed in the Companies Act of 2006 today under the UK Company Law. The Salomon case makes it clear that it is possible for a sole trader owner to transfer a small business into a registered company and hence separate himself from the liabilities of the business. In this case, Salomon carried on a boot and shoe manufacturing business as a sole proprietor. In 1892, he registered a company and sold his profitable business to that company for the purpose of incorporating his business as a limited company of which he was the managing director. To comply with the statute governing company registrations......

Words: 3282 - Pages: 14

Premium Essay

Tax Research

...147(c)(2)(C)(iii)Insolvent farmer.—For purposes of clause (i), farmland which was previously owned by the individual and was disposed of while such individual was insolvent shall be disregarded if section 108 applied to indebtedness with respect to such farmland. 2) Federal Tax Regulations, Regulation, §1.351-1., Internal Revenue Service, Transfer to corporation controlled by transferor Click to open document in a browser | Reg. § 1.351-1 does not reflect P.L. 96–589, P.L. 100-647 or P.L. 101-239. | | (a) (1)   Section 351(a) provides, in general, for the nonrecognition of gain or loss upon the transfer by one or more persons of property to a corporation solely in exchange for stock or securities in such corporation if, immediately after the exchange, such person or persons are in control of the corporation to which the property was transferred. As used in section 351, the phrase "one or more persons" includes individuals, trusts, estates, partnerships, associations, companies, or corporations (see section 7701(a)(1)). To be in control of the transferee corporation, such person or persons must own immediately after the transfer stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 per cent of the total number of shares of all other classes of stock of such corporation (see section 368(c)). In determining control under this section, the fact that any corporate transferor distributes part......

Words: 7212 - Pages: 29

Premium Essay

Taxation of Business Enterprises

...A THOMSON COMPANY ST. PAUL, MINN., 2002 CHAPTER 1 INTRODUCTION Note to prior users: The order of this chapter has been revised. Users who wish to skip the introductory material and begin with the check-the-box regulations may now begin with paragraph 1075. [¶ 1000] A. HISTORY OF THE CORPORATE INCOME TAX This paragraph briefly summarizes the history of the corporate income tax. Some instructors may want to note here that the top corporate income tax rate reached a zenith in 1951 of 52 percent, before being reduced in 1964 to 48 percent, in 1978 to 46 percent, in 1986 to 34 percent (except for corporations with taxable incomes within a specified range that are subject to a top effective marginal rate of 39 percent). The maximum rate was raised in 1993 to 35 percent but only for a relative handful of generally publicly owned corporations earning over $10 million annually. [¶ 1005] B. COMPUTATION OF C CORPORATION'S TAXABLE INCOME This paragraph discusses the computation of a C corporation's taxable income, with particular emphasis on the differences between the computation of a C corporation's taxable income and the computation of an individual taxpayer's taxable income. Some instructors may want to mention here Section 163(j), which limits interest deductions by corporate payors for certain interest paid to exempt parties related to the payor. This provision was added to the Code...

Words: 89224 - Pages: 357

Premium Essay

Hhjh

... A THOMSON COMPANY ST. PAUL, MINN., 2002 CHAPTER 1 INTRODUCTION Note to prior users: The order of this chapter has been revised. Users who wish to skip the introductory material and begin with the check-the-box regulations may now begin with paragraph 1075. [¶ 1000] A. HISTORY OF THE CORPORATE INCOME TAX This paragraph briefly summarizes the history of the corporate income tax. Some instructors may want to note here that the top corporate income tax rate reached a zenith in 1951 of 52 percent, before being reduced in 1964 to 48 percent, in 1978 to 46 percent, in 1986 to 34 percent (except for corporations with taxable incomes within a specified range that are subject to a top effective marginal rate of 39 percent). The maximum rate was raised in 1993 to 35 percent but only for a relative handful of generally publicly owned corporations earning over $10 million annually. [¶ 1005] B. COMPUTATION OF C CORPORATION'S TAXABLE INCOME This paragraph discusses the computation of a C corporation's taxable income, with particular emphasis on the differences between the computation of a C corporation's taxable income and the computation of an individual taxpayer's taxable income. Some instructors may want to mention here Section 163(j), which limits interest deductions by corporate payors for certain interest paid to exempt parties related to the payor. This provision was added to the Code in...

Words: 89224 - Pages: 357

Premium Essay

Glossary

...method of assigning costs to inventory. It includes fixed overhead costs in addition to variable overhead costs added to direct materials and direct labour to calculate unit cost. Accelerated amortization Accelerated amortization is a method of allocating the cost of an asset in which the annual amortization amounts are larger in an asset’s early years and decrease over time. An example of accelerated amortization would be the double-declining balance method. Access controls Procedures designed to restrict access to online terminal devices, programs, and data. Access controls consist of ”user authentication” and ”user authorization.” Account Place within an accounting system where the increases and decreases in a specific asset, liability, owner’s equity, revenue, or expense are recorded and stored. Account analysis An account analysis is the identification of each important item and amount in an account followed by document vouching and inquiry to determine whether amounts should be classified elsewhere. Account balance An account balance is the difference between the increases (including the beginning balance) and decreases recorded in the account. An account...

Words: 115733 - Pages: 463

Premium Essay

Cga Pa2

...method of assigning costs to inventory. It includes fixed overhead costs in addition to variable overhead costs added to direct materials and direct labour to calculate unit cost. Accelerated depreciation Accelerated depreciation is a method of allocating the cost of an asset in which the annual depreciation amounts are larger in an asset’s early years and decrease over time. An example of accelerated depreciation would be the double-declining balance method. Access controls Procedures designed to restrict access to online terminal devices, programs, and data. Access controls consist of ”user authentication” and ”user authorization.” Account Place within an accounting system where the increases and decreases in a specific asset, liability, owner’s equity, revenue, or expense are recorded and stored. Account analysis An account analysis is the identification of each important item and amount in an account followed by document vouching and inquiry to determine whether amounts should be classified elsewhere. Account balance An account balance is the difference between the increases (including the...

Words: 116560 - Pages: 467

Premium Essay

Corperate Finance

...CHAPTER 1 Introduction to Corporate Finance Compensation of corporate executives in the United States continues to be a hot-button issue. It is widely viewed that CEO pay has grown to exorbitant levels (at least in some cases). In response, in April 2007, the U.S. House of Representatives passed the “Say on Pay” bill. The bill requires corporations to allow a nonbinding shareholder vote on executive pay. (Note that because the bill applies to corporations, it does not give voters a “say on pay” for U.S. Representatives.) Specifically, the measure allows shareholders to approve or disapprove a company’s executive compensation plan. Because the vote is nonbinding, it does not permit shareholders to veto a compensation package and does not place limits on executive pay. Some companies had actually already begun initiatives to allow shareholders a say on pay before Congress got involved. On May 5, 2008, Aflac, the insurance company with the well-known “spokesduck,” held the first shareholder vote on executive pay in the United States. Understanding how a corporation sets executive pay, and the role of shareholders in that process, takes us into issues involving the corporate form of organization, corporate goals, and corporate control, all of which we cover in this chapter. 1.1 What Is Corporate Finance? Suppose you decide to start a firm to make tennis balls. To do this you hire managers to buy raw materials, and you assemble a workforce that will produce and...

Words: 7653 - Pages: 31

Premium Essay

Taxation Code

...REPUBLIC ACT NO. 8424 TAX REFORM ACT OF 1997 AN ACT AMENDING THE NATIONAL INTERNAL REVENUE CODE, AS AMENDED, AND FOR OTHER PURPOSES Be it enacted by the Senate and House of Representatives of the Philippines in Congress assembled: SECTION 1. Short Title - This Act shall be cited as the "Tax Reform Act of 1997". SECTION 2. State Policy. – It is hereby declared the policy of the State to promote sustainable economic growth through the rationalization of the Philippine internal revenue tax system, including tax administration; to provide, as much as possible, an equitable relief to a greater number of taxpayers in order to improve levels of disposable income and increase economic activity; and to create a robust environment for business to enable firms to compete better in the regional as well as the global market, at the same time that the State ensures that Government is able to provide for the needs of those under its jurisdiction and care. SECTION 3. Presidential Decree No. 1158, as amended by, among others, Presidential Decree No. 1994 and Executive Order No. 273, otherwise known as the National Internal Revenue Code, is hereby further amended. NATIONAL INTERNAL REVENUE CODE OF 1997 AND ITS AMENDMENTS R.A. No. | TITLE | Date of Approval | Date of Effectivity | R.A. 8424 | The National Internal Revenue Code of 1997 | December 11, 1997 | January 1, 1998  | R.A. 8761 | An Act Imposing The Value-Added Tax on Certain Services Beginning January 1, 2001, Amending for......

Words: 93639 - Pages: 375

Premium Essay

Essential of Accounting

...diXESSE ! The ESSENTIAL ACCOUNTING DICTIONARY SPHINX DICTIONARIES es·sen·tial. ADJ. Of the utmost importance. • The most comprehensive pocket-size dictionary • Easy-to-understand definitions • Written by a leading authority in the field Wit Kate Mooney Accoun ting T and Phra erms ses 300O h MORE TH AN The ESSENTIAL ACCOUNTING DICTIONARY es·sen·tial ADJ. Of the utmost importance. The ESSENTIAL ACCOUNTING DICTIONARY es·sen·tial ADJ. Of the utmost importance. Kate Mooney AN IMPRINT OF SOURCEBOOKS, INC.® NAPERVILLE, ILLINOIS SPHINX PUBLISHING ® www.SphinxLegal.com Copyright © 2008 by Kate Mooney Cover and internal design © 2008 by Sourcebooks, Inc.® All rights reserved. No part of this book may be reproduced in any form or by any electronic or mechanical means including information storage and retrieval systems—except in the case of brief quotations embodied in critical articles or reviews—without permission in writing from its publisher, Sourcebooks, Inc.® All brand names and product names used in this book are trademarks, registered trademarks, or trade names of their respective holders. Sourcebooks and the colophon are registered trademarks of Sourcebooks, Inc.® First Edition: 2008 Published by: Sphinx® Publishing, An imprint of Sourcebooks, Inc.® Naperville Office P.O. Box 4410 Naperville, Illinois 60567-4410 (630) 961-3900 Fax: (630) 961-2168 www.sourcebooks.com www.sphinxlegal.com This publication is designed to......

Words: 156997 - Pages: 628

Free Essay

Jmu Hm 203 Study Guide

...1/13/16 The Basics of the Legal System – Chapters 1 & 4 Sources of Law in the U.S 1. The Constitution * The U.S. Constitution is the supreme law of the land * The U.S Constitution establishes the federal government and enumerates its powers * The body of the constitution * Creates the three branches of government and grants certain powers to each branch * The amendments to the constitution * Protect individual rights by putting limitations on the governments ability to act in certain ways * Amendments protect the government, not private individuals The Legislative Branch * Created by Article 1 of the Constitution * House of Representative * Senate * Responsible for the creation of new laws * Congress is generally responsible for where the money comes from and where the money is spent * All statutes start as BILLS * Bills must be passed by both the House and the Senate * Bills that pass both houses must be signed into law by the president or.. * The president can VETO the bill * If signed by the president the Bill becomes a STATUTE 2. Statues, Codes and Ordinances * Statutes are enacted by Congress and state legislatures * Ordinances are enacted by municipalities and local government agencies * Code = Codified Law = Statute The Executive Branch * Created by Article 2 of the Constitution * President * Vice President * Cabinet Members *......

Words: 17272 - Pages: 70

Premium Essay

Proff

...understanding of risk management and practice of insurance. 1: INTRODUCTION 1.1 Concept of risk 1.2 Types of risks 1.3 Response to risk 1.4 Perils and Hazards 2: RISK MANAGEMENT 2.0 Introduction 2.1 Risk Management 2.2 Nature of Risk Management 2.3 Principles of Risk Management 2.4 Risk Management Policy 2.5 Risk Management Strategies (tools) 2.6 Rules in Risk Management 2.7 Risk Management Process 2.8 Risk Management Problems 2.9 Risk Management Evaluation Techniques 3: INSURANCE 3.1 Historical development 3.2 Insurance mechanism 3.3 Requisites of insurability 3.4 Factors Limiting Insurability of Risks 3.5 Functions of insurance 3.6 Benefits of insurance 4: CLASSES OF INSURANCE 4.1 Life and Health 4.2 Liability 4.3 Property 4.4 Pensions 4.5 Transport 5: THE INSURANCE CONTRACT AND PRINCIPLES 5.1 Insurance contract 5.2 Insurable interest 5.3 Utmost good faith 5.4 Indemnity 5.5 Subrogation 5.6 Contribution 5.7 Proximate cause 6: INSURANCE PRACTICE 6.1 Proposal form 6.2 Policy document 6.3 Premiums 6.4 Renewals 6.5 Claims and disputes 6.6 Reinsurance 7: INSURANCE MARKETS 7.1 Buyers of Insurance 7.2 Intermediaries 7.3 Sellers and suppliers of Insurance 7.4 Problems of Marketing Insurance services. 7.5 Competition in the Insurance Industry 7.6 Alternative to Commercial Insurance 8.0 REGULATION OF INSURANCE SERVICES 8.1 Pre-Independence legislation 8.2 Post-Independence legislation 8.3 Objectives of Regulating......

Words: 28656 - Pages: 115

Premium Essay

Taxation

...Taxation Finance Act 2009 Alan Melville S IT IN TH W EEN ON NO IFT ITI F ED ● ● 15th Annual Edition ● ● Class Tested Over 250 Worked Examples ● Over 250 Exercises and Questions On ACCA, CIPFA, AIA and IFA Reading Lists Taxation Supporting resources For instructors Visit www.pearsoned.co.uk/melville to find valuable online resources • Complete, downloadable Instructor’s Manual For more information please contact your local Pearson Education sales representative or visit www.pearsoned.co.uk/melville We work with leading authors to develop the strongest educational materials in accounting, bringing cutting-edge thinking and best learning practice to a global market. Under a range of well-known imprints, including Financial Times Prentice Hall, we craft high quality print and electronic publications which help readers to understand and apply their content, whether studying or at work. To find out more about the complete range of our publishing please visit us on the World Wide Web at: www.pearsoned.co.uk Taxation Finance Act 2009 Fifteenth edition Alan Melville FCA, BSc, Cert. Ed. Pearson Education Limited Edinburgh Gate Harlow Essex CM20 2JE England and Associated Companies throughout the world Visit us on the World Wide Web at: www.pearsoned.co.uk First published 1995 Fifteenth edition published 2010 © Pearson Professional Limited 1995, 1996 © Financial Times Professional Limited 1997, 1998......

Words: 209871 - Pages: 840

Premium Essay

Kien

...Taxation Finance Act 2009 Alan Melville S IT IN TH W EEN ON NO IFT ITI F ED ● ● 15th Annual Edition ● ● Class Tested Over 250 Worked Examples ● Over 250 Exercises and Questions On ACCA, CIPFA, AIA and IFA Reading Lists Taxation Supporting resources For instructors Visit www.pearsoned.co.uk/melville to find valuable online resources • Complete, downloadable Instructor’s Manual For more information please contact your local Pearson Education sales representative or visit www.pearsoned.co.uk/melville We work with leading authors to develop the strongest educational materials in accounting, bringing cutting-edge thinking and best learning practice to a global market. Under a range of well-known imprints, including Financial Times Prentice Hall, we craft high quality print and electronic publications which help readers to understand and apply their content, whether studying or at work. To find out more about the complete range of our publishing please visit us on the World Wide Web at: www.pearsoned.co.uk Taxation Finance Act 2009 Fifteenth edition Alan Melville FCA, BSc, Cert. Ed. Pearson Education Limited Edinburgh Gate Harlow Essex CM20 2JE England and Associated Companies throughout the world Visit us on the World Wide Web at: www.pearsoned.co.uk First published 1995 Fifteenth edition published 2010 © Pearson Professional Limited 1995, 1996 © Financial Times Professional Limited 1997, 1998......

Words: 230548 - Pages: 923