Taxation of International Transactions-Midterm

Taxation of International Transactions-Midterm - draw...

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Taxation of International Transactions Midterm Tax File Memorandum Format Facts – Determine and state only the facts that are relevant to the issue(s) and necessary for the analysis. Issues – Identify the issues raised by the facts and be specific. Applicable Law – Discuss those legal principles that both strengthen and weaken the client’s case. Begin with the Internal Revenue Code (IRC) because it is the primary authority for tax law. When discussing court cases, present the case facts in such a way as to enable the reader to
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Unformatted text preview: draw analogy with the client facts in other words keep it as simple as you can. Analysis – The analysis should (a) apply applicable law to the facts and (b) address the issue(s). In this section, every proposition should be supported by authority, logic, or plausible assumptions. Conclusion – The conclusion should (a) logically flow from the analysis, and (b) address the issues(s)....
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