RP96-11 The Farm Corporation: What It Is, How It Works, How It Is Taxed

A corporation is an artificial person that is created and operated according to state corporation statutes. It is a separate taxpayer subject to specific and detailed federal, state, and local tax laws. The advice and service of your lawyer are indispensable in organizing and operating a farm corporation. There are three basic forms of farm business organization, the sole proprietorship, the partnership, and the corporation. Variations of these forms have resulted in the limited partnership and the "tax option" corporation. These three basic forms are discussed in this research publication.

Nuovi modelli organizzativi: il caso Valve Corporation

La tesi espone il caso della Valve Corporation, una azienda produttrice e distributrice di Videogiochi. Questa azienda, leader nel suo settore, ha adottato una organizzazione di tipo "flat" ed ha ideato particolari e innovative soluzioni per la produzione dei suoi software. Ha inoltre sviluppato una piattaforma di distribuzione digitale per la vendita online di Videogiochi.

Multimembership and Identity in Writing Centers and in Industry: Examining the Work of Reconciliation in the Michigan Tech Multiliteracies Center and at Kimberly-Clark Corporation

Writing center scholarship and practice have approached how issues of identity influence communication but have not fully considered ways of making identity a key feature of writing center research or practice. This dissertation suggests a new way to view identity -- through an experience of "multimembership" or the consideration that each identity is constructed based on the numerous community memberships that make up that identity. Etienne Wenger (1998) proposes that a fully formed identity is ultimately impossible, but it is through the work of reconciling memberships that important individual and community transformations can occur. Since Wenger also argues that reconciliation "is the most significant challenge" for those moving into new communities of practice (or, "engage in a process of collective learning in a shared domain of human endeavor" (4)), yet this challenge often remains tacit, this dissertation examines and makes explicit how this important work is done at two different research sites - a university writing center (the Michigan Tech Multiliteracies Center) and at a multinational corporation (Kimberly-Clark Corporation). Drawing extensively on qualitative ethnographic methods including interview transcriptions, observations, and case studies, as well as work from scholars in writing center studies (Grimm, Denney, Severino), literacy studies (New London Group, Street, Gee), composition (Horner and Trimbur, Canagarajah, Lu), rhetoric (Crowley), and identity studies (Anzaldua, Pratt), I argue that, based on evidence from the two sites, writing centers need to educate tutors to not only take identity into consideration, but to also make individuals' reconciliation work more visible, as it will continue once students and tutors leave the university. Further, as my research at the Michigan Tech Multiliteracies Center and Kimberly-Clark will show, communities can (and should) change their practices in ways that account for reconciliation work as identity, communication, and learning are inextricably bound up with one another.

America’s Newest Citizen - John Q. Corporation

A Montana Public Radio Commentary by Evan Barrett. Published newspaper columns written by Evan Barrett on this topic, which vary somewhat in content from this commentary, appeared in the following publications: Ravali Republic, July 19, 2014 Missoulian, July 11, 2014 Independent Record, July 16, 2014 Flathead Beacon, July 17, 2014

The Emergence of Partnership Networks in the Enterprise Application Development Industry - A Global Corporation Perspective

Currently, dramatic changes are happening in the IS development industry. The incumbent system developers (hubs) are embracing partnerships with less well established companies (spokes), acting in specific niches. This paper seeks to establish a better understanding of the motives for this strategy. Relying on existing work on strategic alliance formation, it is argued that partnering is particularly attractive, if these small companies possess certain capabilities that are difficult to obtain through other arrangements than partnering. Again drawing on the literature, three categories of capabilities are identified: the capability to innovate within their niche, the capability to provide a specific functionality that can be integrated with the incumbents’ systems, and the capability to address novel markets. These factors are analyzed through a case study. The case represents a market leader in the global IS development industry, which fosters a network of smaller partner firms. The study reveals that temporal dynamics between the identified factors are playing a dominant role in these networks. A cyclical partnership model is developed that attempts to explain the life cycle of a partnership within such a network.

Transfer Pricing in the Decentralized Multinational Corporation

This paper considers how the multinational corporation's transfer price responds to changes in international corporate effective tax rates. It extends the decentralized decision-making analysis of transfer pricing in the context of different tax rates. It adopts and extends Bond's (1980) model of the decentralized multinational corporation that assumes centralized transfer pricing. The direction of transfer price change is as expected, while the magnitude of change is likely to be less than predicted by the Horst (1971), centralized decision-making model. The paper extends the model further by assuming negotiated transfer pricing, where the analysis is partitioned into perfect and imperfect information cases. The negotiated transfer pricing result reverts to the Horst (1971), or centralized decision-making, result, under perfect information. Under imperfect information, the centralized decision-making result obtains when top management successfully informs division general managers or it successfully implements a non-monetary reward scheme to encourage division general managers to cooperate. Under simplifying assumptions, centralized decision-making dominates decentralized decision-making, while negotiated transfer pricing weakly dominates centralized transfer pricing.

International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions

We review and extend the core literature on international transfer price manipulation to avoid or evade taxes. Under negotiated transfer pricing with a viable bargaining structure, including performance evaluation disconnected from the transfer price, divisions voluntarily exchange accurate information to obtain firm-wide optimality, a result not dependent on restraint from exercising internal market power. For intangible licenses, a larger optimal profit shift for a given tax rate change strengthens incentives for transfer pricing abuse. In practice, an intangible's arm's length range is viewed as a guideline, a context where incentives for abuse materialize. Transfer pricing for intangibles obliges greater tax authority scrutiny.

Catalogue of Hebraica and Judaica in the library of the Corporation of the City of London

by A. Löwy