In the videos, we saw how things might work out if The Tax Museum started an Irish subsidiary and transferred ownership of its name to its Irish subsidiary. But the Irish are not the only people deeply interested in tax history! There have also been an abundance of Argentine visitors, such that TTM is considering an Argentine location, El Museo de Impuestos. TTM manufactures faithful reproductions of the first form 1040 for sale in its gift shop, framed in a lovely plastic frame. This is done in Chapel Hill at a cost of $2. These are sold for $10 in Chapel Hill, and the plan is to sell for the same price in Argentina. TTM is considering how the transfer pricing would be done for the sale of these framed tax returns from the US to Argentina. Assume the Argentine tax rate is 25%, the U.S. tax rate is 20%, and there is no FDII, GILTI, withholding taxes, etc. 1. Calculate TTM's tax liability in the US and Argentina with regard to this one product if the transfer price is $ 2, $4, and $8. 2. Calculate TTM's pretax income for the consolidated entity with regard to this one product if the transfer price is $2, $4, and $8. 3. If its objective is revenue maximization, which of these three transfer prices might the Argentine tax authority desire, the U.S. tax authority desire, and TTM desire? 4. How is this different from transfer pricing in the case of the trademark?
In the videos, we saw how things might work out if The Tax Museum started an Irish subsidiary and transferred ownership of its name to its Irish subsidiary. But the Irish are not the only people deeply interested in tax history! There have also been an abundance of Argentine visitors, such that TTM is considering an Argentine location, El Museo de Impuestos. TTM manufactures faithful reproductions of the first form 1040 for sale in its gift shop, framed in a lovely plastic frame. This is done in Chapel Hill at a cost of $2. These are sold for $10 in Chapel Hill, and the plan is to sell for the same price in Argentina. TTM is considering how the transfer pricing would be done for the sale of these framed tax returns from the US to Argentina. Assume the Argentine tax rate is 25%, the U.S. tax rate is 20%, and there is no FDII, GILTI, withholding taxes, etc. 1. Calculate TTM's tax liability in the US and Argentina with regard to this one product if the transfer price is $ 2, $4, and $8. 2. Calculate TTM's pretax income for the consolidated entity with regard to this one product if the transfer price is $2, $4, and $8. 3. If its objective is revenue maximization, which of these three transfer prices might the Argentine tax authority desire, the U.S. tax authority desire, and TTM desire? 4. How is this different from transfer pricing in the case of the trademark?
SWFT Essntl Tax Individ/Bus Entities 2020
23rd Edition
ISBN:9780357391266
Author:Nellen
Publisher:Nellen
Chapter16: Multijurisdictional Taxation
Section: Chapter Questions
Problem 1RP
Related questions
Question
In the videos, we saw how things might work out if The Tax Museum started an Irish subsidiary and transferred ownership of its name to its Irish subsidiary. But the Irish are not the only people deeply interested in tax history! There have also been an abundance of Argentine visitors, such that TTM is considering an Argentine location, El Museo de Impuestos.
TTM manufactures faithful reproductions of the first form 1040 for sale in its gift shop, framed in a lovely plastic frame. This is done in Chapel Hill at a cost of $2. These are sold for $10 in Chapel Hill, and the plan is to sell for the same price in Argentina. TTM is considering how the transfer pricing would be done for the sale of these framed tax returns from the US to Argentina.
Assume the Argentine tax rate is 25%, the U.S. tax rate is 20%, and there is no FDII, GILTI, withholding taxes, etc.
1. Calculate TTM's tax liability in the US and Argentina with regard to this one product if the transfer price is $ 2, $4, and $8.
2. Calculate TTM's pretax income for the consolidated entity with regard to this one product if the transfer price is $2, $4, and $8.
3. If its objective is revenue maximization, which of these three transfer prices might the Argentine tax authority desire, the U.S. tax authority desire, and TTM desire?
4. How is this different from transfer pricing in the case of the trademark?
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