商务信件格式范文 Business Letter Sample 商务函电
I have been engaged to review Black Carpet Partnership's (BCP) and Blact Carpet Limited's (BCL) tax returns that had been filed by your in-house accountant, and to classify the costs of BCP's and BCL's costs to determine which are capital and which are revenue for tax purposes.
In the Notice of Proposed Adjustment (NOPA) of the Commissioner of Inland Revenue (CIR), it disallowed all deductions for the project of Timaru plant, because as far as it concerned all of the costs are part of one large capital project, but deductions for certain types of expenditures which can meet the provisions in s DA 1(1) Income Tax Act 2007 (ITA) (formerly section BD 2 (1) (b) (i) and (ii) ITA 1994).
As we know, what is deduction in s DA 1 is determined by a general permission of the ITA 2007. Certainly there are some specific limitations(called the general limitations) in s DA 2 for this general permission. In section DA 3, there are also specific provisions which may supplement or override the general permission and override any or all of the general limitations.
Our work is in line with s DA 1 to s DA 3, as well as other common expenses which may refer to.
Before I prepare for, or respond to, any formal correspondence to the CIR or Inland Revenue on your behalf, I should give you some advice. These advice includes the various expenses that should be tax deductible or capitalised, and the restructuring of BCP into BCL.
At first, we should notice the specific time of the Timaru plant project and the time of restructure of BCP to BCL. You should prepare the legal documents to testify that before the restructure of BCP to BCL the Timaru project was already began. From the facts and assumptions provided to me, I found that the Timaru project started in January 2007, and the total work will take eighteen months. That is to say, it lasted from 2007 to the fist half of 2008. But the restructure of BCP to BCL effected from 1 July 2008, at that time, the Timaru project was ended. Therefore in my opinion, you should testify these facts.
Secondly, the NOPA of CIR thought that the costs of Timaru project should be capitalised as they form part of one large project, the CIR even thought the restructuring of BCP to BCL is tax avoidance. It is obviously bad for the reputation of your company. In my view, we should take the NOPA seriously, and review the every parts of the project to response the NOPA.
On the one hand, the project is not only for the business of BCP/BCL, it is also in order to meed the changed environment protection standards. For example, the standards for earthquakehttp://www.ukthesis.org/Thesis_Writing/MBAliuxueshengzuoye/ protection and building codes, the tower structure has to be tested according to these updated standards. On the other hand, we should stress the special features of the products of BCP/BCL. As we know, the main products of BCP/BCL is asphalt and bitumen, which is bulky, heavy materials with a high scouring effect. In order to produce safely, the regularly re-check of the equipments and plant is very important in the asphalt making process. Furthermore, the raw materials of BCP, which is chemical materials, may have potential danger should be handled with properly.(责任编辑：charlie)