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Surviving the IRS: How to Resolve Your Tax Debt Without Going Broke

為了解決IRS foreign的問題，作者LL M., Jason Carr 這樣論述：

Jason Carr is a tax attorney with a practice primarily focused on representing individuals in domestic and foreign tax compliance issues, including reporting foreign assets and defending against penalties. He also assists clients that have run afoul of the IRS or other agencies while investing in cr

yptocurrencies. In addition to tax clients, Jason represents a select number of entrepreneurs, artists and athletes in business and personal matters. He is a member of the Texas Bar Association’s Tax Section and is a published author on tax-related topics.

Tax Havens: International Tax Avoidance and Evasion

為了解決IRS foreign的問題，作者Gravelle, Jane G. 這樣論述：

Addressing tax evasion and avoidance through use of tax havens has been the subject of a number of proposals in Congress and by the President. Actions by the Organization for Economic Cooperation and Development (OECD) and the G-20 industrialized nations also have addressed this issue. In the 111th

Congress, the HIRE Act (P.L. 111-147) included several anti-evasion provisions, and P.L. 111-226 included foreign tax credit provisions directed at perceived abuses by U.S. multinationals. Numerous legislative proposals to address both individual tax evasion and corporate tax avoidance have been adv

anced. Multinational firms can artificially shift profits from high-tax to low-tax jurisdictions using a variety of techniques, such as shifting debt to high-tax jurisdictions. Because tax on the income of foreign subsidiaries (except for certain passive income) is deferred until income is repatriat

ed (paid to the U.S. parent as a dividend), this income can avoid current U.S. taxes, perhaps indefinitely. The taxation of passive income (called Subpart F income) has been reduced, perhaps significantly, through the use of hybrid entities that are treated differently in different jurisdictions. Th

e use of hybrid entities was greatly expanded by a new regulation (termed check-the-box) introduced in the late 1990s that had unintended consequences for foreign firms. In addition, earnings from income that is taxed often can be shielded by foreign tax credits on other income. On average, very lit

tle tax is paid on the foreign source income of U.S. firms. Ample evidence of a significant amount of profit shifting exists, but the revenue cost estimates vary substantially. Evidence also indicates a significant increase in corporate profit shifting over the past several years. Recent estimates s

uggest losses that may approach, or even exceed, ＄100 billion per year. Individuals can evade taxes on passive income, such as interest, dividends, and capital gains, by not reporting income earned abroad. In addition, because interest paid to foreign recipients is not taxed, individuals can evade t

axes on U.S. source income by setting up shell corporations and trusts in foreign haven countries to channel funds into foreign jurisdictions. There is no general third-party reporting of income as is the case for ordinary passive income earned domestically; the Internal Revenue Service (IRS) relies

on qualified intermediaries (QIs). In the past, these institutions certified nationality without revealing the beneficial owners. Estimates of the cost of individual evasion have ranged from ＄40 billion to ＄70 billion. The Foreign Account Tax Compliance Act (FATCA; included in the HIRE Act, P.L. 11

1-147) introduced required information reporting by foreign financial intermediaries and withholding of tax if information is not provided. These provisions became effective only recently, and their consequences are not yet known. Most provisions to address profit shifting by multinational firms wou

ld involve changing the tax law: repealing or limiting deferral, limiting the ability of the foreign tax credit to offset income, addressing check-the-box, or even formula apportionment. President Obama's proposals include a proposal to disallow overall deductions and foreign tax credits for deferre

d income, along with a number of other restrictions. Changes in the law or anti-abuse provisions have also been introduced in broader tax reform proposals. Provisions to address individual evasion include increased information reporting and provisions to increase enforcement, such as shifting the bu

rden of proof to the taxpayer, increased penalties, and increased resources. Individual tax evasion is the main target of the HIRE Act, the proposed Stop Tax Haven Abuse Act, and some other proposals.

Quizizz結合學生小組成就區分法對國小三年級英語單字學習成效之影響

為了解決IRS foreign的問題，作者施慧玟 這樣論述：

本研究旨在探討即時反饋系統Quizizz結合學生小組成就區分法對國小三年級英語單字學習成效之影響。本研究使用準實驗研究法，以桃園市某公立國小三年級學生為研究對象，受試學生分為三組，實驗組1學生接受Quizizz結合學生小組成就區分法教學，實驗組2學生接受Quizizz結合直接教學法教學，控制組學生接受直接教學法教學，進行為期八週共十六節課的實驗課程，並以英語單字成就測驗卷作為研究工具，測量學生在實驗教學前後測成績之差異。本研究以相依樣本t檢定、二因子共變數分析進行資料處理，並根據學生學後訪談、教師課堂觀察記錄對於結果輔以討論。研究結果如下：一、 三組學生在接受不同教學策略後，單字學習成效皆

顯著提升。二、 教學策略與學生英語程度沒有對單字學習成效產生交互作用，影響單字學習的主要原因為教學策略。三、 學生在接受Quizizz結合學生小組成就區分法後，單字學習成效優於其他兩組，其中拼寫能力的進步最為顯著。最後根據本研究結果提出建議，供相關教育工作者及未來研究者參考。