LO.3, 5 BlueCo, a domestic corporation, incorporates GreenCo, a new wholly owned entity, in Germany.Under both German and U.S. legal principles, this entity is a corporation. BlueCo faces a 21% U.S. tax rate.GreenCo earns $1,500,000 in net profits from its German manufacturing activities and makes no dividenddistributions to BlueCo. How much U.S. income tax must BlueCo pay for the current year as a result ofGreenCo's earnings, assuming that it triggers no constructive dividend under Subpart F?

Since GreenCo is a wholly-owned foreign subsidiary of BlueCo, because no constructive dividend is…

Answered: LO.3, 5 BlueCo, a domestic corporation,…

SWFT Comprehensive Volume 2019

42nd Edition

ISBN:9780357233306

Author:Maloney

Publisher:Maloney

Chapter25: Taxation Of International Transactions

Section: Chapter Questions

Problem 16P

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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.
Drake, Inc., a domestic corporation, has worldwide taxable income of $250,000, consisting of $200,000 U.S.-source income and $50,000 foreign-source dividend income from Jetco, a foreign corporation in which Drake owns 4% of the voting stock. The foreign tax paid on the dividend income is $20,000. a. What is the limit on the foreign tax credit? b. What is the US and total tax paid by Drake?
5.
P Corporation is the U.S.-based parent of F Company, a French-based branch. If P Corporation has U.S. taxable income of $100,000 and F Company has a $20,000 loss, what is P Corporation’s worldwide taxable income?
Subject:
Axtell Corporation has the following taxable income: U.S. source income Foreign source income: Country A Country B Country C Taxable income $ 1,620,000 550,000 2,000,000 2,900,000 $ 7,070,000 Axtell paid $600,000 income tax to Country B and $1.3 million income tax to Country C. Country A does not have a corporate income tax. Required: Compute Axtell's U.S. income tax, assuming the foreign source income does not qualify as FDII. Note: Do not round any intermediate calculations. Enter your answer in dollars and not in millions of dollars. U.S. income tax
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
2. Summer Corporation’s business is international in scope and is subject to income taxes in a foreign country. Summer’s earnings and income taxes paid in Brazil $1,900,000 and $595,000 respectively. Summer’s earnings in Ireland were $1,000,000, where income tax of $100,000 was paid. If Summer Corporation’s worldwide income subject to taxation in the United States is $5,000,000 and the U.S. income tax due prior to the foreign tax credit is $1,050,000. Explain the purpose of the foreign tax credit and describe how it is computed. Compute the allowable foreign tax credit, and the US tax liability after the credit. If, instead, the total foreign income taxes paid were $550,000 (450,000 in Brazil plus 100,000 in Ireland), compute the allowable foreign tax credit.
Spartan Corporation, a U.S. corporation, reported $6.2 million of pretax income from its business operations in Spartania, which were conducted through a foreign branch. Spartania taxes branch income at 15 percent, and the United States taxes corporate income at 21 percent. Required: a. If the United States provided no mechanism for mitigating double taxation, what would be the total tax (U.S. and foreign) on the $6.2 million of branch profits? b. Assume the United States allows U.S. corporations to exclude foreign source income from U.S. taxation. What would be the total tax on the $6.2 million of branch profits? c. Assume the United States allows U.S. corporations to claim a deduction for foreign income taxes. What would be the total tax on the $6.2 million of branch profits? d-1. Assume the United States allows U.S. corporations to claim a credit for foreign income taxes paid on foreign source income. What would be the total tax on the $6.2 million of branch profits? d-2. Assume the…
Please guide to helping solve D, and E. thank you!
Transcom, an Ohio corporation, earned $700,000 U.S. source income from sales of goods to U.S. customers and $330,000 foreign source income from sales of goods to customers in Canada. Canada's corporate income tax rate is 15 percent, and the United States and Canada have a bilateral tax treaty. Required: a. Compute Transcom's U.S. tax if it does not maintain a permanent establishment in Canada. Assume the foreign source income does not qualify as FDII. b. Compute Transcom's U.S. tax if it does maintain a permanent establishment in Canada. Complete this question by entering your answers in the tabs below. Required A Required B Compute Transcom's U.S. tax if it does not maintain a permanent establishment in Canada. Assume the foreign source income does not qualify as FDII. U.S. income tax Required A Required B >
San Carlos Corporation, a U.S. multinational, had pretax U.S. source income and foreign source income as follows: U.S. source income $ 400,000 Foreign source income—Country W 300,000 Total $ 700,000 San Carlos paid $60,000 income tax to Country W. Assume San Carlos’ foreign source income does not qualify as foreign-derived intangible income. Calculate San Carlos' tax savings if it takes a foreign tax credit rather than deducting this tax. $100,000 $66,000 $47,400 $0

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