LO.3 Willa, a U.S. corporation, owns the rights to a patent related to a medical device. Willa licenses the rightsto use the patent to IrishCo, which uses the patent in its manufacturing facility located in Ireland. What is thesourcing of the $1,000,000 royalty income Willa received from IrishCo for the use of the patent?

The sourcing of royalty income is determined by the location of the property that generates the…

Answered: LO.3 Willa, a U.S. corporation, owns…

SWFT Comprehensive Vol 2020

43rd Edition

ISBN:9780357391723

Author:Maloney

Publisher:Maloney

Chapter25: Taxation Of International Transact Ions

Section: Chapter Questions

Problem 21P

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8. Molly, Inc., a domestic corporation, generates income from the receipt of royalty income from patents that it owns. Molly wants to avoid U.S. income tax on these royalties, so it has its 100%-owned subsidiary, based in Nigeria, hold the patents and collect the royalties. What U.S. income tax issues must be considered in assessing this arrangement by Molly, Inc.?
10 The following persons are your clients: Who is allowed to claim deduction? Nicanor, an employee of ABC Corp. ABC Corp, a foreign corporation doing business in the Philippines XYZ Corp. a foreign corporation based in Europe Inday Manoban, a Thai-Korean and member of the PinkBlack K-Pop Group based in Korea Group of answer choices Inday Nicanor XYZ Corp ABC Corp
If the decedent was a nonresident alien and his country exempts a Filipino citizen from estate tax, how much of his assets would be subject to reciprocity? P1,000,000 P800,000 P600,000 P350,000
Mang Antoy sold his land located in Bulacan to Mang Batak, who intends to use the land as site of his ABC Factory. Mang Batak paid P500,000 to Mang Antoy for the land which has a fair market value of P700,000 at the date of sale. How much would be the tax on the transfer of ownership?
The following persons are your clients: Who is allowed to claim deduction? • Nicanor, an employee of ABC Corp. • ABC Corp, a foreign corporation doing business in the Philippines XYZ Corp. a foreign corporation based in Europe • Inday Manoban, a Thai-Korean and member of the PinkBlack K-Pop Group based in Korea Choices Inday Nicanor XYZ Corp АВС Corp
5. Uste company owns a condominium unit in "The One Residences" which is near the factory and the plant' s administrative building. To make it convenient to its executive, it allowed the latter to use the said property as his residence. The zonal value of the property is P32 000 000 while its fair market value as shown in its current real property tax declaration amounts to P25 000 000. How much is the fringe benefits expense? How much is the fringe benefit tax expense? 2/2
The following persons are your clients: Who is allowed to claim deduction? - Nicanor, an employee of ABC Corp. - ABC Corp, a foreign corporation doing business in the Philippines - XYZ Corp. a foreign corporation based in Europe - Inday Manoban, a Thai-Korean and member of the PinkBlack K-Pop Group based in Korea a. Nicanorb. ABC Corpc. XYZ Corpd. Inday
BTS Corporation owns a residential house with a fair market value of $10,000,000 and a carrying amount of $8,000,000 for 2018. GIRLS GEN, a US citizen assigned to work in the Philippines for a 5 year contract was allowed to use the same. How much is the FBT due for the year 2020 on the said house benefit, if any? a. $134,615 b. $107,682 c. $269,231 d. None of the choices
26.)
18
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.
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 dividend distributions to BlueCo. How much U.S. income tax must BlueCo pay for the current year as a result of GreenCo's earnings, assuming that it triggers no constructive dividend under Subpart F?

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