Reference no: EM132624388

Question - The Oceana ITA defines taxable income as the taxpayer's aggregate net income from all sources for the year. Income is defined as income according to ordinary concepts.

The ('NARA') operates a tourist resort in the island state of Oceania. Many of the company's guests come from Japan. In an effort to upgrade the service provided to guests, NARA engages Language Instruction Ltd ('Lanis') to deliver an introductory course in the Japanese language. Lanis prepares a course of 18 one hour lessons. The course runs for six weeks with three lessons each week held for one hour immediately following the conclusion of the day shift at 5.00 p.m. All front line staff are required to participate in the course. NARA pays Lanis $1,000 per employee taking the course.

Jojo is an employee of NARA working on the resort's reception desk. She participates in the course and acquires the ability to engage in simple conversations in Japanese.

SHIKA, (a competitor of NARA) also operates a resort that has many guests from Japan. Shortly after completion of the Lanis course, SHIKA offers Jojo a job paying double her salary at NARA. Jojo resigns her employment with NARA and commences working for SHIKA.

In calculating Jojo's taxable income for the year should we include some figure with respect to the free language training received by Jojo?