Internal revenue code section 482 and Transfer Pricing Free Essay Example, 2500 words

These provisions clearly state that the prices and fees charged by such entities for the goods, services or loans as well as property, that they will transfer between different associates of the company, should be same as they would have done if the transaction was with a business house outside the company group. However, what could be these prices etc. for the transfer transaction remains a big question. Certain anomalies are found between the legislations laid out under section 482 and the implementation of the same. The reasons for this can be summarized as below: Section 482 legislation and the regulations for implementation of the same are working diversely as these regulations are ambiguous, thus vulnerable to many interpretations by the revenue officials. While dealing with the issues of intra-company pricing, the need is to have experts in the economic and financial fields to decide and implement the section 482 according to its true legislative meaning. However, the dearth of such expertise with IRS results in varied implementation of the legislation and thus the resolution of any pricing issue becomes a subject of multiple interpretations. The other reason could be that the US congress, which has passed such legislative laws like section 482 of IRC code, have provided that these laws mandate the availability of expertise and sources to IRS for interpreting and implementing the rules in the proper manner. We will write a custom essay sample on Internal revenue code section 482 and Transfer Pricing or any topic specifically for you Only $17.96 $11.86/page The legislations could be the result of certain political motivation also, while keeping in view the interests of some individual members. .... .... .... .... .... .... .(Transfer pricing, book by King page 5-7 ) Disparity between section 482 legislation and administrative practice There can be several reasons for such disparity. One reason is the glaring gap between the actual tax collections and the figures that were mandated for such tax hauls. If it is the fault on part of the administrative and treasury deptt. ,. for improper implementation, then either the tax laws or the administrative practices need to be reformed to bring the two closer. However, if the US congress is collectively satisfied with the actual tax collections that show huge deficit of collection from the large companies, then the legislation can be only a â€Å"window dressing† exercise, which means a costly revenue loss.

The Current Status Of The Millennium Development Goals

What possible reasons may there be to explain the fact that although the GDP per capita annual growth rates were negative over the period, the HDI value still increased. HDI stands for the Human Development Index and GDP stands for gross domestic product. Even though a positive GDP will lead to a higher HDI value, a negative GDP per capita growth rate doesn’t necessarily mean the HDI value will decrease. There are other factors which contribute to a high HDI value, not just the GDP rate. These include life expectancy, education, mortality rates, and gender equality. So, it is possible that there is still a positive HDI value even though the GDP per capita annual growth rates were decreasing. You may be asked to outline the current status of the Millennium Development Goals. You will find short progress reports on each of the 8 goals. Now Read through the reports Create your own summary report One of the greatest challenges that people need to face is to eradicate extreme poverty. Even though some progress has been made, over 800 million people live on less than $1.25 USD a day. The progress that has been made has been uneven with statistics showing that more women are in need of shelter, water, and other basic needs than men. Education has proved to have a direct correlation to economic development, which is why it has become one of the Millennium Development Goals. Progress has been made, with enrolment rate reaching 91%. However, nations won’t stop until every childShow MoreRelatedPakist Child Health And Mortality1658 Words   |  7 Pageshealth of Pakistani children. Development Status In order to improve the health and poverty status of Pakistan, the United Nations Development Program has been a major partner of the Pakistan Government to help them achieve the internationally set anti-poverty Millennium Development Goals (MDGs). The eight MDGs range from ensuring environmental sustainability to improving maternal health and achieving universal primary education (â€Å"Millennium Development Goals†). Pakistan has adopted 41 indicatorsRead MoreCountry Portfolio Of Nigeri Nigeria1120 Words   |  5 Pagesunderstanding about Nigeria’s status and health progress after the creation of the Millennium Development Goals (MDG), information has been gathered about socioeconomic data, health indicators, and priority goals. Socioeconomics and Demographic Profile The current socioeconomics for Nigeria are extreme poverty and it is estimated around 62% of it current population live below its poverty line, which equates to under $1 day a day (Nigerian Millennium Development Goals, 2015). Nigeria’s gross domesticRead MoreEssay on Childrens Health: The Key to the Future1706 Words   |  7 Pagescountries. In response to improving the overall health status of the world, the 191 United Nation members developed the Millennium Development Goals in 2000. The eight distinctive but interrelated goals can be accomplished to alleviate the world suffering such as poverty, hunger, disease, illiteracy, and environmental degradation (United Nations Children’s Fund [UNICEF], 2011). A country’s continuous endeavor to meet the Millennium Development Goal Four conveys the commitment to improve and modify itsRead MoreIs Water a Human Right?1445 Words   |  6 Pagesaffront to human dignity.† — Kofi Annan, prior United Nation s Secretary-General †¦ If only the issue of water as a human right was as simple as Kofi Annan’s perspective. A world where humans have a well defined set of undeniable rights is an important goal for this generation. But aside from rights, the human race has a more dire set of biological needs that it must secure in order to survive. When someone is denied a right, they suffer. When someone is denied a need, they die. Air, food and water areRead MoreEvaluating the Millenium Development Goals1723 Words   |  7 PagesIn the present study we evaluate the Millennium Development Goals (MDGs) as a framework for measuring development and assess how India and its states are doing in terms of the MDGs. The global community and the UN are busy reviewing the Millennium declaration during ten years into the new millennium. There is a race of the nations to attain their MDGs. Many countries around the world are part of this project and making independent assessment of their country situation. The achievement of the MDGsRead MoreSolving The Foreclosure Crisis1291 Words   |  6 PagesOn its surface, the current foreclosure crisis appears to have erupted from a volatile mix of debt, deregulation, risk, and over-leveraging within the economy. This; however, is a merely symptomatic approach to the recession, and does not address its underlying causes. 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Energy was not explicitly considered in the Millennium Development Goals in 2000 or the Johannesburg Plan of Implementation in 2002. Howe ver the link between energy services and poverty reduction was clearly identified, as energy services and modern cooking fuels improved as a result (UNDP, 2005, PG.8). January 2016 will bring into effect the United Nations (UN) 17 sustainable development goals to transformRead MoreSocial And Economic Problems Faced By Michigan1099 Words   |  5 PagesJust because people try to do good and do their best to promote a safe, equal, and problem-free society, does not mean that it is possible. In this essay I plan to explore the social and economic problems faced my Michigan as they entered the new millennium and the history of special education in Michigan. The constitution of 1850 stated, â€Å"institutions for the benefit of those inhabitants who are deaf, blind, dumb, or insane shall always be fostered and supported† (Ziewacz, 164). Michigan A HistoryRead MoreAfghanistan s Development Of Afghanistan Essay1766 Words   |  8 Pagesthreatens the survival of the state. For many, they are the wild west where there is no law and anything goes. While there is some truth to that, Afghanistan faces serious problems in their quest towards becoming a developed nation. The Millennium Development Goals were created by the United Nations to help countries stabilize and develop faster in order to catch up with the rest of the world. It was also a matter of universal human rights and speaking up for those whose voices could not be heard

The Last Remnants of Grizzly Bears Free Essays

With all the new and advanced technology that is accessible today, who has time to enjoy or care about the great outdoors? Unfortunately, much of the wilderness and the animals within it are gradually fading away. There are many animals that have already been extinct and many more will soon be put on the list of extinction. In the second issue of Target Earth, Tim Stevens found in 1975, the grizzly bear was listed as a threatened species, under the Endangered Species Act. We will write a custom essay sample on The Last Remnants of Grizzly Bears or any similar topic only for you Order Now Stevens also stated, Today, the grizzly bear hangs on in the last remnants of wild places left in the U. S. –places like the Greater Yellowstone, Glacier Park, and Shelkirk Mountains of Northern Idaho. The survival of the grizzly bear depends on several factors such as: amount of food they need and amount of space they need to live. Grizzly bears have tremendous food requirements in order to survive–adult females average 300 pounds, and males around 450 pounds, stated Stevens. Furthermore, grizzly bears are opportunistic feeders thriving on roots, berries, pine nuts, insects, herbaceous vegetation, fish, small mammals, and occasionally wild ungulates and their young. With grizzly bears wide variety of provisions, they need a large area to sustain themselves. Stevens stated, a male grizzly bear will use up to a 500 square mile â€Å"home range† throughout its life. Glover and Johnson stated, a female grizzly bear will use up 11-490 square miles throughout its life. Being that the grizzly bear is a wide-ranging, slow breeding species, and as such, are very good indicators of the overall health of the ecosystems they depend upon. If the habitat is in good shape, one could assume the bear is doing rather well(Stevens, Target Earth). However, conservation biologist states, none of the current grizzly populations is large enough to sustain itself over time. Aldo Leoplod states, the most feasible way to enlarge the area available for wilderness fauna is for the wilder parts of the National Forests, which usually surround the Parks, to function as parks in respect of threatened species. Leopold goes on to state, they have not so functioned is tragically illustrated in the case of the grizzly bear. The Greater Yellowstone is isolated from other wildland ecosystems. These populations become vulnerable to inbreeding and other genetic problems, it is critical to have these grizzly bear ecosystems connected by â€Å"linkages† or â€Å"biological corridors. † Ecosystems are much larger than the designated national parks within them. At the core of the Greater Yellowstone National Park, which is 2. 2 million acres. The ecosystem is 18 million acres and includes 7 national forests, wilderness areas, national wildlife refuges and Bureau of Land Management land. Bears are not only dependent upon the National Park â€Å"core,† but also upon the surrounding lands. Scientists have long recognized that these species are dependent upon the health of the entire ecosystem(Stevens, Target Earth). The grizzly bears habitat is slowly diminishing. The Northeast part of Greater Yellowstone provides a good example of the overall cumulative effects that many activities can have on an area. This area has been one of the best and most productive regions for grizzly bears. However, the U. S. Forest Service has been steadily logging and roading many of the last non-wilderness public lands in the region. For example, in one area called the Sunlight Basin, nearly, 4,500 acres of trees have been harvested since 1986. All of this timber was in grizzly habitat. Unfortunately, more timber sales are planned for this are in the future(Stevens, Target Earth).. In addition, on our national forest lands, logging and mining companies and willing federal agencies continue the steady drumbeat of resource extraction. Logging, road building and other developments have begun to invade and alter these landscapes, reducing their ability to support grizzly bears in two critical ways: first, transforming large expanses of land into smaller patches that will be isolated from each other. If the remaining patches become separated by too great a distance, populations of grizzly bears will inevitably decline and may disappear altogether. Second, development brings humans in to the habitat of bears, which inevitably leads to more disturbance and illegal bear kills. It is this kind of scenario that is typical of the remaining 2% of grizzly habitat in the United States(Stevens, Target Earth). Furthermore, when we protect habitat for the grizzly bear, we are also protecting other non-game species, clean water, big game habitat and places for people to experience the wonder of creation. Protecting the last 2%of grizzly bear habitat in the lower 48 states is a delicate balancing act. In the 20 years since the grizzly bear was listed as a threatened species, habitat critical to its survival has been steadily eroded, through clear-cutting, excessive forest road building, oil and gas drilling and private development. Stevens states, proper balance and conservation of grizzly habitat is the key to the bears future. The grizzly bear is one of Yellowstone’s most popular attractions. It is a symbol of the rugged west. At one time, populations were thought to be between 50,000 and 100,000 bears in the 1800s in North America. However, by 1900, only a few bears remained in scattered areas. In 1975, the U. S. Fish and Wildlife Service listed less than 1,000 bears remained. Today, biologist report 280-610 grizzlies inhabit the Greater Yellowstone ecosystem. This estimate comes from a study team of the Interagency Grizzly Bear Committee(Glover and Johnson). Today, there are many organizations and efforts to preserve the grizzly bears for the generations to come. One such organization is the Eastern Slopes Grizzly Bear Project. This project was initiated in 1994 to address the urgent need for scientific information about the cumulative effect of human development and activities on grizzly bears in this area. The ESGBP actively promotes the application of this information in management and conservation contexts. One of the objectives of the ESGBP is to focus on research efforts on the cumulative effects of regional land use and mortality factors on grizzly bears. Another objective is to contribute to the conservation of grizzly bear populations and their habitat in the Central Rockies Ecosystems and especially the eastern Slopes(Canadianrockies). If a plan is not devised to help promote and preserve the wildlife of the grizzly bears, it may not be long before they are taken off the Endangered Species list and placed on the extinction list. Author Edward Abbey stated, â€Å"It is my fear that if we allow the freedom of the hills and the last of the grizzly to be taken away from us, then the very idea of freedom may die with it†. And, â€Å"We must not allow our national parks and national forests to be degraded to the status of mere playgrounds†. Grizzly bears obviously need a large space for survival being their provisions range from a wide variety of nuts and berries. Also, the adult females only produce every three years due to the fact their young stay with them for two years. This is one reason why grizzly bears do not reproduce rapidly. Grizzly bears are the second slowest reproducing land mammal in North America. By keeping the grizzly bear from becoming extinct, it protects many other animals from becoming extinct as well. How to cite The Last Remnants of Grizzly Bears, Essay examples

Classroom Assessment in Fifth Grade Science free essay sample

A study was conducted to explore the hypothesis that performance assessments foster a more positive motivational orientation for students than supplied-response assessments which tend to truncate students’ learning strategies (Parkes Stefanou, 2003). We will write a custom essay sample on Classroom Assessment in Fifth Grade Science or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page This was in response to general dissatisfaction arising from large-scale, high-stakes multiple choice testing, particularly among the older students who experienced higher levels of anxiety and mistrust with respect to standardized tests.   It partook of a cost-benefit analysis of the consequences of this particular type of assessment procedure to determine whether the positive outweighed the negative. Traditional paper and pencil tests (PP), a laboratory task format of assessment (lab), and a performance assessment (PA) were imposed on three different fifth grade science classes, particularly involving Goal Orientations to supply quantitative data.   Qualitative output was also obtained through taped interviews of the three classes.   Quantitatively, goal orientation seemed to be influenced by the type of assessment used. When paired with the qualitative data, students seemed to perform well in PP testing because they equated a good grade with competence and ability, and they believed that performing well in PP testing reflected this competency (Parkes Stefanou, 2003).   However, if receiving grades was removed from the equation, students became more receptive to PA testing and were motivated to take risks and explore actually doing science rather than just knowing science (Parkes Stefanou, 2003). One of the limitations of the study was that qualitative information was necessary to complete the picture presented by the quantitative data.   Although the study was by no means definitive as to whether or not assessment types contributed to student motivation, it clearly showed that when paired with the stakes or consequences attributed to the assessment results, it affects the students’ goal orientations. Reference List Parkes, J. and Stefanou, C. (2003). Effects of classroom assessment on student motivation on fifth-grade science. The Journal of Educational Research, 96 (3), 152-162.