1) Real Property Income of Foreign Persons T, a nonresident alien, is a shareholder of X Corp., whose assets consist of a retailing business in Canada and stock of Y Corp. Y’s principal asset is an office building in Miami, but it also holds a portfolio of stocks and bonds of Canadian corporations. How might IRC section 897 apply to gain recognized by T on a sale of her X Stock if, alternately: a) X holds 40 percent of Y’s stock, and alternatively: i) X and Y are both domestic corporations? ii) X is a domestic corporation, and Y is a foreign corporation? iii) X is a foreign corporation, and Y is a domestic corporation? b) X holds 60 percent of Y’s stock, and alternatively: i) X and Y are both domestic corporations? ii) X is a domestic corporation, and Y is a foreign corporation? iii) X is a foreign corporation, and Y is a domestic corporation? 2) U.S. Tax Reform, Doing Business in the U.S. and Foreign Persons FC is foreign corporation organized in the Republic of Ireland and recently listed on the Euronext Dublin Stock Exchange. FC will organize a Delaware C corporation that will manufacture and distribute product in the U.S. market. FC’s Vice President of Tax recently contacted you to discuss doing business in the United States. He/she raised several questions as follows: a) As it will take at least 1 year to build out a U.S. manufacturing facility FC is considering having Irish based employees travel to the U.S. to meet with current third-party distributors for business development meetings – the VP of Tax asked whether this creates potential U.S. tax issues for FC? Please describe; b) FC would like to fund the new U.S. operations with a combination of debt and equity – the VP of Tax read something about U.S. interest disallowance rules and asked whether such rules would apply to its new U.S. operations. Please elaborate; c) FC will charge its U.S. operations for management services. The U.S. operations will also purchase raw materials from FC that will be used in the manufacturing process. The VP of Tax asked whether the BEAT could apply to its U.S. operations. Please explain whether the BEAT could apply to FC’s U.S. operations; and d) On potential interest, royalty and dividend payments from the U.S. operations to FC, the VP of Tax asked you to describe how the U.S. withholding tax rules should apply. Please explain the application of the U.S. withholding tax rules as well as the potential application of the U.S.-Ireland Income Tax Treaty.

 

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week 6 Amazon Web Services (AWS) has a series of white papers
available for download. For this discussion thread, you will download the white
paper, “How Cities Can Stop Wasting Money, Move Faster, and Innovate.”

To access this white paper, please go to the following url:

https://aws.amazon.com/whitepapers/

This white paper is the eighth paper on the website. Please
scroll down to this particular white paper and click download Whitepaper.

This white paper is organized in a similar fashion as other
white papers you have read in this class. It has a title page, a table of
contents on page 4, an abstract on page 4, and then the body of the white paper
on pages 5-16. It does not cite any sources, but rather uses testimonies from
various cities and municipalities to give credibility to its claims.

Please answer the following questions, answering each one in
one to three sentences or so.

1. Who is the audience for this white paper? In other words,
what potential clients is it trying to attract?

2. Examine pages 5-7. Is this white paper “marketing” AWS a
bit too much? Remember the lecture from Mak Pandit in which he noted that the
presentation should be “neutral” and “marketing should be subtle.” Please use
one or two examples of words or phrases from pages 5-7 and explain whether you
feel Amazon is being subtle here.

3. Notice the headings in the white paper. They are not
typical academic headings. They are designed to catch the reader’s attention.
This strategy resonates with a strategy given in the Purdue OWL lecture. What
strategy did the Purdue OWL mention in this regard?

4. Please comment on whether the graphics in this white
paper help communicate the message. You can see Figure 1 on page 6 and Figure 2
on page 14.

5. Various cities are mentioned in this white paper. The
white paper first mentions three cities and one county in the United States
(McKinney, Texas; Asheville, North Carolina; and King County in Washington
State; and Boston, Massachusetts). It then mentions locations outside of the
United States—Moovit in Israel, Transport for London, and the London City
Airport.

Is there a strategy as to why a particular city or location
is mentioned in any particular part of the white paper? In answering this
question, you can select one city or location and analyze why it was mentioned
in the particular section of the white paper in which it was mentioned.

 

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Internal erosion is a major contributor to failure of embankment dams. Failure can occur

within the embankment, its foundations or at the interface between the embankment and

its foundation. Design considerations for internal erosion requires the provision of effective

filters, in addition to assessing the susceptibility of available construction material and natural foundation material to internal erosion. In this assessment, you will explore laboratory

assessment of internal erosion, the design of an effective filter zone and assess the susceptibility to suffusion in a laboratory setting. This will require your knowledge of seepage through

embankments and its foundations covered in previous coursework and assessments.

1

Requirements

You are required to work independently and prepare a report that addresses all the questions

set out below. All work towards any component of the report must be conducted solely by

you. The report must be submitted via Blackboard by 12pm Wednesday 20 May 2020,

along with the signed EAIT coversheet which can be accessed here.

Submit a PDF that contains either handwritten responses (ensuring that any handwritten

responses are neat and clearly legible) or a typed document that provides all of the steps

and assumptions made to attain the solution. The PDF file should have the following file

name convention:

{STUDENT_ID}_{FULL_NAME}_Assessment_03_CIVL7225.pdf

In addition, any external document that was required to obtain the solution, such as Excel

spreadsheet, MATLAB scripts/notebooks or Python scripts/notebooks, must also be submitted via Blackboard. Use an appropriate naming convention for these supplementary files.

For example:

{STUDENT_ID}_{FULL_NAME}_Assessment_03_CIVL7225_Q1_EXCEL.xlsx

 

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Write a function comp10001huxxy_valid_play() which takes five arguments:

• play, a 3-tuple representing the play that is being attempted; see below for details;
• play_history, a list of 3-tuples representing all plays that have taken place in the game so far (in chronological order); each 3-tuple is based on the same structure as for play;
• active_player, an integer between 0 and 3 inclusive which represents the player number of the player whose turn it is to play;
• hand, a list of the cards (each in the form of a 2-character string, as for Q1) held by the player attempting the play;
• table, a list of list of cards representing the table (in the same format as for Q2).

Your function should return a Boolean indicating whether the play is valid or not given the current game state (i.e. the combination of the plays made to date, the content of the player’s hand, and the groups on the table). In this, you only need to validate the state of the table (using comp10001huxxy_valid_table from Q2, which you are provided with a reference implementation of) if the play ends the player’s turn and they have played to the table. Note that play_history, hand, and table all represent the respective states prior to the proposed play being made (e.g. play_history will not contain play).

The composition of the 3-tuple used to represent each play is (player_turn, play_type, play_details), where player_turn is an integer (between 0 and 3 inclusive) indicating which player is attempting to play, and play_type and play_details are structured as follows, based on the play type:

• pick up a card from stock (and thereby end the turn): play_type = 0, play_details = None;
• play a card from the hand to the table: play_type = 1, play_details = (card, to_group) where card is the card from the hand that is to be played, and to_group is the (zero-offset) index of group in table to play to; in the instance that the card is to start a new group, to_groupshould be set to the one more than the index of the last group on the table (i.e. if there are three groups, the last group will be index 2, so 3 would represent that the card is to be used to start a new group);
• play a card from one group on the table to another: play_type = 2, play_details = (card, from_group,to_group) where card is the card to be played from the group, from_group is the (zero-offset) index of the group in table to play card from, and to_group is the index of the group in table to play card to (and, similarly to above, a value of one more than the index of the last group indicates that a new group is to be formed)
• end the turn, after playing from the hand or play between groups on the table: play_type = 3, play_details = None.

Note that picking up a card (play_type = 0) implicitly ends the turn, whereas if plays are made from the hand/between groups on the table, an explicit “end of turn” play (play_type = 3) must be used to confirm that the player is ending their turn.

Example function calls are as follows:

>>> comp10001huxxy_valid_play((0, 0, None), [], 0, [‘3S’, ‘KC’, ‘8C’, ‘3S’, ‘8S’, ‘KH’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [])

True

>>> comp10001huxxy_valid_play((0, 1, (‘KC’, 0)), [], 0, [‘3S’, ‘KC’, ‘8C’, ‘3S’, ‘8S’, ‘KH’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [])

True

>>> comp10001huxxy_valid_play((0, 1, (‘KC’, 1)), [], 0, [‘3S’, ‘KC’, ‘8C’, ‘3S’, ‘8S’, ‘KH’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [])

False # invalid group no.

>>> comp10001huxxy_valid_play((0, 1, (‘AC’, 0)), [], 0, [‘3S’, ‘KC’, ‘8C’, ‘3S’, ‘8S’, ‘KH’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [])

False # can’t play card you don’t hold

>>> comp10001huxxy_valid_play((0, 1, (‘KH’, 0)), [(0, 1, (‘KC’, 0))], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘KH’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [[‘KC’]])

True

>>> comp10001huxxy_valid_play((0, 1, (‘KD’, 0)), [(0, 1, (‘KC’, 0)), (0, 1, (‘KH’, 0))], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [[‘KC’, ‘KH’]])

True

>>> comp10001huxxy_valid_play((0, 2, (‘KS’, 1, 0)), [(0, 1, (‘KC’, 0)), (0, 1, (‘KH’, 0))], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [[‘KC’, ‘KH’]])

False # group/card don’t exist

>>> comp10001huxxy_valid_play((0, 3, None), [(0, 1, (‘KC’, 0)), (0, 1, (‘KH’, 0)), (0, 1, (‘KD’, 0))], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’], [[‘KC’, ‘KH’, ‘KD’]])

True

>>> comp10001huxxy_valid_play((0, 3, None), [], 0, [‘3S’, ‘KC’, ‘8C’, ‘3S’, ‘8S’, ‘KH’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [])

False # attempt to end turn without any plays to table

>>> comp10001huxxy_valid_play((0, 3, None), [(0, 1, (‘KC’, 0)), (0, 1, (‘KH’, 0))], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [[‘KC’, ‘KH’]])

False # table state not valid

>>> comp10001huxxy_valid_play((0, 3, None), [(0, 1, (‘AC’, 0)), (0, 1, (‘AH’, 0)), (0, 1, (‘AD’, 0))], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’], [[‘AC’, ‘AH’, ‘AD’]])

False # insufficient points for opening turn

>>> comp10001huxxy_valid_play((0, 1, (‘KS’, 0)), [(0, 1, (‘KC’, 0)), (0, 1, (‘KH’, 0)), (0, 1, (‘KD’, 0)), (0, 3, None), (1, 0, None), (2, 0, None), (3, 0, None), (0, 0, None), (1, 0, None), (2, 0, None), (3, 0, None)], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KS’], [[‘KC’, ‘KH’, ‘KD’]])

True

>>> comp10001huxxy_valid_play((0, 3, None), [(0, 1, (‘KC’, 0)), (0, 1, (‘KH’, 0)), (0, 1, (‘KD’, 0)), (0, 3, None), (1, 0, None), (2, 0, None), (3, 0, None), (0, 0, None), (1, 0, None), (2, 0, None), (3, 0, None), (0, 1, (‘KS’, 0))], 0, [‘3S’, ‘8C’, ‘3S’, ‘8S’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’], [[‘KC’, ‘KH’, ‘KD’, ‘KS’]])

True

>>> comp10001huxxy_valid_play((1, 0, None), [], 0, [‘3S’, ‘KC’, ‘8C’, ‘3S’, ‘8S’, ‘KH’, ‘4H’, ‘2C’, ‘6S’, ‘5H’, ‘8C’, ‘KD’], [])

False # wrong player

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