AC566 Unit 10 Tax Research Portfolio Example

Five Pieces, One Verification Date: A Unit 10 Tax Research Portfolio With a Cover Memo on What Changed

[Student Name]

Purdue University Global

AC566: Tax Research and Intro to International Taxation

Unit 10 Research Portfolio

[Instructor Name]

[Date]

The clients and every figure are composite; the statutes, cases, ruling, model conventions and textbook cited are real; this is coursework, not tax advice.

Cover Memo

To: Course Instructor and Supervising Partner From: Tax Associate Date: May 6, 2027 Re: Research portfolio, revised and re-verified

This portfolio collects five pieces written during the term: the Unit 1 research question on an employment settlement, the Unit 3 citator workpaper on Gitlitz, the Unit 4 staking memorandum, the Unit 6 sourcing table and the Unit 9 treaty analysis. Each has been revised, and every authority cited in any piece was re-verified on May 4, 2027, using the same citator. The purpose is to make the work consistent enough that a reviewer could rely on any piece without asking who wrote it or when.

Consistent Standards Applied

Four standards were applied to every piece. First, each states its facts, issue, conclusion and confidence in that order, so a reviewer always knows where to look. Second, every authority is cited in the same format and ranked by weight in the analysis, with primary authority before secondary. Third, every case and ruling was checked for later history and treatment on the same date. Fourth, each conclusion states what fact, if different, would change it.

Piece 1: The Settlement Question

What changed. The graded version ended with a framed issue. The revision adds the answer: the $55,000 for emotional distress is taxable apart from what she spent treating the distress, because section 104(a)(2) excludes only damages on account of physical injury or sickness (Compensation for injuries or sickness, 26 U.S.C. § 104, 2018). It also adds a fact the client later supplied, $4,200 of therapy costs, which are excludable. Why: the original stopped at framing because the unit asked only for that; the portfolio needs a usable conclusion.

Piece 2: The Citator Workpaper

What changed. The graded version reported Gitlitz as superseded by statute. Re-verification found no new treatment. The revision adds a paragraph on the attribute reduction rules that follow from the amended statute, which the original mentioned only in passing, because the client's practical concern was losing her suspended losses (Gitlitz v. Commissioner, 2001). Why: a citator result is only useful if it is carried through to what the client should expect.

Piece 3: The Staking Memorandum

What changed. The graded version's confidence was stated as high. The revision keeps that but adds that the 2023 ruling was re-verified as not modified or revoked as of May 4, and notes a pending administrative proposal on digital asset reporting that does not affect the timing of income (Internal Revenue Service, 2023). The original also gave the gain on sale without stating its holding period; the revision labels it short-term. Why: confidence statements need a date, and a reviewer should not have to infer the holding period.

Piece 4: The Sourcing Table

What changed. The graded version sourced the manufactured inventory under the pre-2018 split rule in one draft and the current production rule in another. The revision applies the current rule consistently: income from inventory produced in Ohio and sold abroad is entirely US source (Income partly from within and partly from without the United States, 26 U.S.C. § 863, 2018). That lowered foreign-source gross income to $515,000 throughout. Why: an earlier draft relied on a secondary source written before the change, which the citator check of the statute exposed.

Piece 5: The Treaty Analysis

What changed. The graded version concluded that no permanent establishment existed. The revision separates the dependent agent analysis, where that conclusion probably holds under the treaty's older wording, from a new home office analysis that the original missed, where a fixed place permanent establishment is a real risk (OECD, 2017). Why: the instructor's comment asked whether the reimbursed home office mattered, and on re-reading Article 5 it does.

The revisions share a pattern: each original answered the question the unit asked, and each revision answers the question the client actually has, which is the difference between an assignment and research someone could rely on.

What the Re-Verification Found

Of the twenty-three authorities cited across the five pieces, twenty-one showed no change. One secondary source used in an early draft of the sourcing table was outdated and has been removed. The 2024 Supreme Court decision ending automatic deference to agency interpretations, cited in the authority hierarchy exercise and relevant to how much weight regulations now carry, was noted in the staking and settlement pieces where regulations play a role (Loper Bright Enterprises v. Raimondo, 2024).

What I Would Do Differently From the Start

Three habits would have avoided most of the revisions. Verify every authority on the day a piece is finished, not at the end of the term. Write the conclusion for the client's actual question even when the assignment asks for less. And read the source documents, such as contracts and treaty text, before relying on summaries (Sawyers & Gill, 2021).

How the Pieces Fit Together

Read together, the five pieces trace a full research cycle. The settlement question shows how to frame an issue before searching. The citator workpaper shows why a case found online must be checked before it is relied on. The staking memorandum shows the standard memo structure and how to state confidence. The sourcing table shows the domestic rules that underlie any international question, and the treaty analysis shows how a treaty can override them and how fragile a conclusion can be when the treaty's wording is old. A reviewer can open any piece and find the same order: facts, issue, conclusion, analysis and confidence.

Limits of the Portfolio

The pieces are coursework on composite clients. They are written as if for a supervising partner, but none has been reviewed by one, and none should be relied on for a real client without checking the client's own facts and any law that has changed since May 4, 2027. Each piece states its key assumptions so that a reader can see where different facts would lead to a different answer. Two pieces, the staking memorandum and the treaty analysis, rest most heavily on assumptions: the first on the client's ability to withdraw rewards immediately, the second on the treaty's unamended wording.

Index

The pieces follow in the order above, each headed by its revision note, with the graded version attached behind it for comparison.

References

Compensation for injuries or sickness, 26 U.S.C. § 104 (2018).

Gitlitz v. Commissioner, 531 U.S. 206 (2001).

Income partly from within and partly from without the United States, 26 U.S.C. § 863 (2018).

Internal Revenue Service. (2023). Revenue Ruling 2023-14 (Internal Revenue Bulletin 2023-33). U.S. Department of the Treasury.

Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024).

OECD. (2017). Model tax convention on income and on capital: Condensed version 2017. OECD Publishing. https://doi.org/10.1787/mtc_cond-2017-en

Sawyers, R. B., & Gill, S. L. (2021). Federal tax research (12th ed.). Cengage.