A U.S. corporation owning 100 percent of a Dutch corporation will be eligible for a foreign tax credit for Dutch withholding taxes imposed on dividends received from the corporation even if the dividend is eligible for the 100 percent dividends received deduction. Group startsTrue or FalseTrue, unselectedFalse, unselected

A U.S. corporation owning 100 percent of a Dutch corporation will be eligible for a foreign tax credit for Dutch withholding taxes imposed on dividends received from the corporation even if the dividend is eligible for the 100 percent dividends received deduction. Group startsTrue or FalseTrue, unselectedFalse, unselected

SWFT Essntl Tax Individ/Bus Entities 2020

23rd Edition

ISBN:9780357391266

Author:Nellen

Publisher:Nellen

Chapter16: Multijurisdictional Taxation

Section: Chapter Questions

Problem 20P

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Similar questions

U.S. corporations are eligible for a foreign tax credit for withholding taxes imposed on dividends received from 100 percent owned foreign corporations, even if the dividend qualifies for the 100 percent dividends received deduction. True or False
Which statement is true concerning an individual who is a US tax resident and a corporation that is a US tax resident? A. Both an individual who is a US tax resident and a corporation that is a US tax resident pay US income tax on their Worldwide. B. An individual who is a US tax resident pays US income tax only on US sources income and very limited foreign source income while a corporation that is a US tax resident pays US income tax on its worldwide income. C. An individual who is a US tax resident pays US income tax on his worldwide income while a corporation that is a US tax resident pays US income tax only on US source income and very limited foreign source income. D. Both an individual who is a US tax resident and a corporation that is a US tax resident pay US income tax on their worldwide. E. Both an individual who is a US tax resident and a corporation that is a US tax resident pay US income tax only on US source income
Which of the following items of foreign source income is classified as passive category income for foreign tax credit purposes? Multiple Choice Dividend received from a 5 percent owned foreign corporation, all of the income of which is derived from an active business. Dividend received from a 20 percent owned foreign corporation, all of the income of which is derived from an active business. Dividend received from a 100 percent owned foreign corporation, all of the income of which is derived from an active business. None of the dividends in the scenarios listed here are classified as passive category income.
Dividend income received by a domestic corporation from a nonresident foreign corporation may be exempt from income tax, provided: The dividends actually received or remitted into the Philippines are reinvested in the business operations of the domestic corporation within the next taxable year from the time the foreign-source dividends were received or remitted; The dividends received shall only be used to fund the working capital requirements, capital expenditures, dividend payments, investment in domestic subsidiaries, and infrastructure project; and a. b. C. d. The domestic corporation holds directly at least twenty percent (20%) in value of the outstanding shares of the foreign corporation and has held the shareholdings uninterruptedly for a minimum of two (2) years at the time of the dividends distribution. In case the foreign corporation has been in existence for less than two (2) years at the time of dividends distribution, then the domestic corporation must have continuously…
Determine the correct tax treatment of the following dividends
In order to simplify the tax code, current regulations require that a dollar of income earned by a U.S. Corporation in the United States is taxed in the same way as a dollar of income earned by a U.S. Corporation in a foreign country. Select one: True False
If the nation in which the nonresident foreign corporation is domiciled permits a credit for taxes presumed paid in the Netherlands equivalent to 15%, dividend received from a domestic corporation by a nonresident foreign corporation shall be subject to a final tax of 15%.
Which of the following gain is subject to capital gains tax? * a. Gain on sale of domestic bonds considered as capital asset. b. Gain on sale of real property considered as capital asset which is located in the Philippines. c. Gain on sale of foreign stocks not traded through the stock exchange O d. All of the above 9 O e. Both a and b only
2. Liang Corporation, a U.S. entity, owns 100% of ForCo, a non-U.S. corporation not engaged in a U.S. trade or business. Is Liang subject to any U.S. income tax on her dealings with ForCo? Explain.
SHOULD BE PHILIPPINES BASED 1. What are the ordinary and capital assets? 2. Enumerate the two types of capital assets subject to capital gains tax. 3. What are the transaction considered as "other disposition" of domestic stocks? What transactions are not considered as "other dispositions? 4. Discuss the rules on tax basis of stocks acquired by purchase, inheritance, donation, for inadequate consideration, and other tax-free exchange.
U.S. International Corporation (USIC), a U.S. taxpayer, has investments in Foreign Entities A-G. Relevant Information for these entities for the current fiscal year appears in the following table: Entity Country % Owned Activity Income before tax ($ millions) Income Tax Rate Dividend Withholding tax Rate Net Amount Received by Parent ($ millions) USIC United States 35.00% Argentina Brazil Canada Hong Kong 100% Liechtenstein 100% A B C D E F G 100% 100% 100% 51% Japan New Zealand 60% Manufacturing $10.00 Manufacturing $1.00 Manufacturing $2.00 Manufacturing $3.00 Investment $2.00 Distribution $3.00 Manufacturing $2.00 $4.00 Banking 35.00% 34.00% 26.00% 16.50% 10.00% 38.00% 28.00% 0% 0% 5% 0% 4% 5% 5% $0.20 $2.50 $1.00 $1.50 S- $0.50 $1.00 Additional Information 1. USIC's $10 million income before tax is derived from the production and sale of products in the United States. 2. Each entity is legally incorporated in its host country other than Entity A, which is registered with the…
According to OCED , a number of countries are considered "Tax Havens" which contribute to tax revenue lost to other countrie Which one of the following country/region is NOT listed among the top 10 list? O a. Hong Kong O b. United States O c. Switzerland O d. United Kingdom Under the US tax code, when an American company merged with a foreign entity (i.e., Ireland), the global income from this newly merged company is no longer subject to US corporate tax. What is the processed called? a. Tax evasion O b. Income tax planning O c. None of the above O d. Corporate Inversion