Partial liquidations takes place when there is a contraction or reduction of a corporation’s business activities. Complete liquidations occur at the end of a corporation’s life cycle. Surprisingly, the IRS Code does not define what complete liquidation is. Instead, Treasury regulations indicate that a complete liquidation exists for tax purposes. … when the corporation ceases to be a…
Corporate Stock Redemption
A stock redemption occurs when a shareholder sells stock back to the issuing corporation for cash or property. A redemption raises many important and potentially complex tax issues. If the shareholder who redeem stocks is the only shareholder, a stock redemption has no effect on his proportionate ownership interest in the corporation. In this case, if this redemption…
My 138th certificate from Coursera
Foundations of Business Intelligence Google Business Intelligence (BI) has been there for decades, there are already quite a few mature products available on the shelf. Even at this moment AI and machine learning are hotter and buzzier, BI still has its own place that no one else can challenge the value and impact of BI….
Foundations of Business Intelligence
The term business intelligence dates back to 1865, when it appeared in the encyclopedia of commercial and business anecdotes. Business intelligence (BI) involves automating processes and information channels in order to transform relevant data into actionable insights that are easily available to decision-makers. By showing decision-makers what is currently happening, organizations become more intelligent and successful. Careers in BI BI…
Discrete Optimization: Linear Programming
Invented by聽George Dantzig in 1947, Linear Programming is one of the most fundamental tools in combinatorial optimization. You have two views: the geometrical view and the algebraic view.聽There are beautiful connection between them. This is what a linear program looks like, which is minimizing a linear objective function and is subject to a set of…
Corporate Non-Liquidating Distribution
As corporations operate, they can share their economic successes with shareholders by making distributions. However distributions are not necessarily required and different firms have different incentives and disincentives. From a tax perspective, it is necessary to classify distribution as: The term non-liquidating distribution implies that the distributions are not in an effort to wind up the affairs of the…
Discrete Optimization: Local Search
Previously we talked about constraint programming, which actually works with partial assignments, we try to extend them, and to prune search space as much as possible. Another method, called local search, is very different. Simply put, local search is moving the configuration from it’s聽current state to a state which is very close to it, i.e….
Taxation for Corporation Formation: Liabilities, Capital and Loss
Along with assets, corporate formation also routinely involves the transfer and assumption of liabilities. The corporation is taking responsibilities for such liabilities, but an important tax issue arises. Does the assumption of liabilities by the corporation (transferee) constitute boot received by the shareholder (transferer)? Assumption of Liabilities Recall that in addition to the stock of corporation, shareholders can also…
My 137th certificate from Coursera
Modernizing Data Lakes and Data Warehouses with Google Cloud Google Cloud Recently, the concept Lakehouse is really drawing people’s attention. It combines the best elements of data lakes and data warehouses. But what is data lake? If you image a scenic view in which there is a beautiful lake and a house nearby, that will…
Data Lakes and Data Warehouses in Google Cloud
A data engineer is someone who builds data pipelines. They want to get their data into a place, such as a dashboard or report or machine learning model, from where the business can make data-driven decisions. Transactional Databases vs. Data Warehouse Data engineers may be responsible for both: Be aware that Cloud SQL is optimized to…
Taxation: Non-Recognition Rules for Corporate Formation
Important tax issues arise throughout the corporate lifecycle: its formation, operation and liquidation. The formation of a corporation generally involves the transfer of assets and liabilities by one or more persons in exchange for stock in the newly formed corporation. Property Transaction IRC subchapter O: Gain or Loss on Disposition of Property defines the rules for property…
Discrete Optimization: Constraint Programming
Constraint Programming is one of the main paradigms to actually tackle optimization problems. The idea is to look at the problem constraints, and try to use constraints to reduce the set of values that each variables can take, and remove the values that can not appear in any solution. Constraint programming can help model problems…
My 136th certificate from Coursera
DevOps, DataOps, MLOps Duke University If you are kinda fed up with training models and would like to try some new perspectives and build some new skills, MLOps is a very good point to start with. I personal felt like falling down to a rabbit hole when I took this course. Nowadays, the ecosystem for…
Introduction to MLOps
You probably have known the DevOps methodology which is very commonly used in the software industry, which basically deploy your infrastructure programmatically, do continuous integration, test your code automatically, deploy the software continuously in production. Overall the software is constantly being updated with new features and then you have the ability to make changes in…
Corporate Income Taxation
Regular Income Tax Liability The regular tax liability calculation itself is very straightforward: The complexity of corporate income tax thus stems from the rules and regulations that shape and define the tax base, i.e. corporate taxable income. For tax years beginning after 2017, the Tax Cuts and Jobs Act reduced the corporate tax rate to…