380 research outputs found
A new Arabic fragment of Jacob of Serugh’s homily On Epiphany
This contribution presents a new Arabic fragment of Jacob of Serugh’s homily On the Baptism of Our Saviour in the Jordan (On Epiphany). It has been preserved through secondary use in the back cover of MS Sinai, St Catherine's Monastery, Ar. 516 and can be attributed palaeographically to the Sinaitic scribe Thomas of Fustat. The translation belongs to the oldest translations of Jacob's works into Arabic. The text was previously only known from two other short fragments. The new fragment doubles the amount of known text of this translation. It is contextualised in detail here and the text is reproduced in a diplomatic edition and English translation.Esta contribución presenta un nuevo fragmento árabe de la homilía de Jacobo de Sarug Sobre el Bautismo de Nuestro Salvador en el Jordán (Sobre la Epifanía). El fragmento se ha conservado gracias a un uso secundario en la cubierta trasera del manuscrito del Monasterio de Santa Catalina del Sinaí, Sin. Ar. 516 que se puede atribuir paleográficamente al copista sinaítico Tomás de Fustat. La traducción pertenece a las traducciones más antiguas de las obras de Jacobo al árabe. Hasta ahora, el texto sólo se conocía por otros dos breves fragmentos. El nuevo fragmento duplica la cantidad del texto conocido de esta traducción. En esta contribución se contextualizará detalladamente el fragmento y se reproducirá el texto en una edición diplomática acompañado de su traducción inglesa
Accuracy of Hotel Feasibility Study Projections
Hotel feasibility studies are critical in the determination of hotel construction, sales and refinancing. Discrepancies have been reported between forecasted results and actual operating results. The author, with funding provided by the Hilton corporation, examines whether such studies under- state or overstate occupancy, average rate, and net income
Property Exchange Rules Offer Tax Opportunities for Hotel Owners
One strategy often overlooked by hospitality owners in developing cost-saving strategies is the use of like-kind exchanges to acquire property. The author reviews some alternative methods of like-kind exchanges, which may not only provide new business opportunities for the hospitality owner, but lucrative tax benefits as well
Using Tax Incentives Reduces Construction Costs
Rehabilitation tax credits can save developers a significant amount of money. The author discusses the tests used to lower overall tax liability by renovating older structures
Planning Buy-Sell Agreements In The Hospitality Industry
In the article - Planning Buy-Sell Agreements In The Hospitality Industry - by John M. Tarras, Assistant Professor, School of Hotel, Restaurant and Institutional Management at Michigan State University, the author initially observes: “The vast majority of hospitality firms (restaurants, hotels, etc.) would be considered closely-held corporations. As such, they have unique planning problems compared to large, publicly-traded hospitality firms. One area of special concern to the closely-held hospitality firm is the planning and adoption of a buy-sell agreement.”
The above thesis statement outlines the heart of the article; the buy-sell agreement in regard to smaller [closely held, as Tarras calls them] corporations.
The theory is narrow and pro-active, spanning the gap between personal-to-corporate stock manipulations.
“The primary purpose of a buy-sell agreement is to contribute to the orderly transfer of a shareholder\u27s stock in a hospitality firm upon some future incident [typically retirement, withdrawal of a shareholder, disability, or death], as Tarras defines the concept.
“The hospitality firm or the other shareholders would be committed to purchase the departing shareholder\u27s stock at an agreed upon price and method, and to ensure that ample cash will be obtainable for such an impending sale. The buy-sell agreement provides a market for the shareholder or the shareholder\u27s estate for the sale of otherwise illiquid stock,” the author further provides as canons of buy-sell agreements.
In defining the buy-sell agreement with restrictive clauses, Tarras demonstrates, “…many closely-held hospitality firms desire to limit ownership to those individuals, either family or principal corporate employees, who are essential to the well-being of the firm.”
Tarras says, another element of the buy-sell agreement is to furnish the departing shareholder with liquidity. “…there typically is some form of cash down payment with the remainder denoted by an interest-bearing promissory note [usually 5 to 15 years],” he informs. “The departing shareholders may require that the hospitality firm pledge the assets of the firm and that the remaining shareholders personally guarantee the promissory note.”
“…the most frequent reason for establishing buy-sell agreements is for estate planning purposes,” Tarras says.
There are tax advantages and liabilities for both the seller and buyer of stock via the buy-sell agreement, and the author enumerates many of these.
One, big advantage of the buy-sell agreement is that it provides for the running of the company with a minimum of disruption through the stock-cash transition process, Tarras offers
IRS Looks Closely at Independent Contractors
The IRS is using various tools to attack the status of various so-called \u27outside consultants being used by hospitality firms. This article will provide some planning tips so that the hospitality firm can minimize its chances of having workers reclassified as employees
The IRS Collection Division: Contacts and Settlements
In his study -The IRS Collection Division: Contacts and Settlements - by John M. Tarras, Assistant Professor School of Hotel, Restaurant and Institutional Management, Michigan State University, Tarras initially states: “The collection division of the internal revenue service is often the point of contact for many hospitality businesses. The author describes how the division operates, what the hospitality firm can expect when contacted by it, and what types of strategies firms might find helpful when negotiating a settlement with the IRS.”
The author will have you know that even though most chance meetings with the IRS Collection Division are due to unfortunate tax payment circumstances, there are actually more benign reasons for close encounters of the IRS kind. This does not mean, however, that brushes with the IRS Collection Division will end on an ever friendlier note.
“…the Tax Reform Act of 1986 with its added complexity will cause some hospitality firms to inadvertently fail to make proper payments on a timely basis,” Tarras affords in illustrating a perhaps less pugnacious side of IRS relations.
Should a hospitality business owner represent himself/herself before the IRS? Never, says Tarras. “Too many taxpayers ruin their chances of a fair settlement by making what to them seem innocent remarks, but ones that turn out to be far different,” warns Professor Tarras.
Tarras makes the distinction between IRS the Collection Division, and IRS the Audit Division. “While the Audit Division is interested in how the tax liability arose, the Collection Division is generally only interested in collecting the liability,” he informs you. Either sounds firmly in hostile territory.
They don’t bluff. Tarras does want you to know that when the IRS threatens to levy on the assets of a hospitality business, they will do so. Those assets may extend to personal and real property as well, he says. The levy action is generally the final resort in an IRS collection effort.
Professor Tarras explains the lien process and the due process attached to that IRS collection tactic.
“The IRS can also levy a hospitality firm owner\u27s wages. In this case, it is important to realize that you are allowed to exempt from levy 25 per week for each of your dependents (unless your spouse works),” Professor Tarras says with the appropriate citation.
What are the options available to the hospitality business owner who finds himself on the wrong side of the IRS Collection Division? Negotiate in good faith says Professor Tarras. “In many cases, a visit to the IRS office will greatly reduce the chances that a simple problem will turn into a major one,” Tarras advises. He dedicates the last pages of the discussion to negotiation strategies
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