Click to see additional instructions Piper, a US citizen owns 100% of the stock of FORCO, a foreign manufacturing and sales subsidiary. In 2020, FORCO had $10 million of income from the manufacturing and sale of widgets in Europe and paid $3 million in foreign income taxes. FORCO distributed no dividends. In January of 2020, FORCO invested/deposited $7 million with a US Bank earning 1% annual interest (US sourced income). What are the U.S. tax consequences (if any) to Piper? • Piper must include in gross income her share of FORCO's Subpart F income (Investment of Earnings in US Property), which is

SWFT Comprehensive Vol 2020
43rd Edition
ISBN:9780357391723
Author:Maloney
Publisher:Maloney
Chapter25: Taxation Of International Transact Ions
Section: Chapter Questions
Problem 34P
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Piper, a US citizen owns 100% of the stock of FORCO, a foreign manufacturing and sales subsidiary. In 2020, FORCO had $10 million of
income from the manufacturing and sale of widgets in Europe and paid $3 million in foreign income taxes. FORCO distributed no
dividends. In January of 2020, FORCO invested/deposited $7 million with a US Bank earning 19% annual interest (US sourced income).
What are the U.S. tax consequences (if any) to Piper?
• Piper must include in gross income her share of FORCO's Subpart F income (Investment of Earnings in US Property), which is
Transcribed Image Text:Click to see additional instructions Piper, a US citizen owns 100% of the stock of FORCO, a foreign manufacturing and sales subsidiary. In 2020, FORCO had $10 million of income from the manufacturing and sale of widgets in Europe and paid $3 million in foreign income taxes. FORCO distributed no dividends. In January of 2020, FORCO invested/deposited $7 million with a US Bank earning 19% annual interest (US sourced income). What are the U.S. tax consequences (if any) to Piper? • Piper must include in gross income her share of FORCO's Subpart F income (Investment of Earnings in US Property), which is
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