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Presentation: Taxation A tax event English for accountancy Mister Gershon Feldman , CPA Preformed by: Amir H. Liran K. Elyashiv B. Semester A 5770

Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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Page 1: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

Presentation:

Taxation

A tax event

English for accountancy

Mister Gershon Feldman , CPAPreformed by:

Amir H.

Liran K.

Elyashiv B.

Semester A – 5770

Page 2: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

2

Projects objectives

– Demonstrating aspects of the essential

dimension of a tax event by showing

examples from the Israeli Tax ordinance and

from familiar law cases in Israel and the

world.

Page 3: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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Tax definition

Briefly:

A fee charged by a government on a

product, income, or activity.

*uk.etrade.com

Page 4: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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What is the purpose of taxation?

The main purpose. raise money to -Revenuespend on roads, schools and hospitals, and on more

indirect government functions like market regulation

or legal systems.

• Redistribution- transferring wealth from

the richer sections of society to poorer sections.

• Repricing- Taxes are levied to deal with

externalities.

For example, on tobacco → to discourage smoking

• Representation- rulers tax citizens, and

citizens demand accountability from their rulers

→ "no taxation without representation"

:The Four "R"s

Page 5: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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What is a tax event?

• The essential

dimension

• The chronological

dimension

• The international

dimension

Page 6: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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The essential dimension

• Conversion of stocks to fixed asset?

The Israeli Tax ordinance:

• Claus 85: We shell se this as a tax event.

Page 7: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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Law cases

Page 8: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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The story

Mrs Sharkey had a horse's farm in order to

raise and then sell them. Mrs Sharkey moved

some horses to her privet farm in order to

make a privet use- for horse racing.

Sharkey v Wernher

Page 9: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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The basic question in the court's discussion:

Court’s new

termination

Court's explainCourt’s

answer

“A notional

sell”

".. Someone who moves some of

his business' stocks to his privet

"garage" is actually selling the

business' stocks to himself and

this is just like he was selling the

stocks to a foreign”

YES

" can someone trade with him self ? "

This sentence was a revolutionary sentence

Sharkey v Wernher

Page 10: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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The story

A building apartments company.

They had A few apartments that weren’t

sold. They have turned them to rental

apartments until the company will

succeed selling those apartments.

Gan Chana Leaa Roz

Page 11: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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Court’s new

termination

Court's explainWho won

the case

“Temporary

change of

use”

The change of use is

temporary.

The event does not

enter Clause 85.

The

company

Gan Chana Leaa Roz

The income tax assessor: There is a change of the apartment’s

(company's stocks) use → A tax event according to Clause 85.

: It is not a change of use, the apartments The company

are still for sell.

Page 12: Presentation: Taxation A tax eventhomedir.jct.ac.il/~elyashib/MyProjects...Presentation: Taxation A tax event English for accountancy Preformed by: Mister Gershon Feldman , CPA Amir

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thank you for attending our

presentation!