PRINCIPLES OF TAXATION F/BUS.+INVEST.
22nd Edition
ISBN: 9781259917097
Author: Jones
Publisher: MCG
expand_more
expand_more
format_list_bulleted
Question
Chapter 11, Problem 2AP
To determine
Identify the corporations which forms an affiliated group eligible to file a consolidated tax return.
Expert Solution & Answer
Want to see the full answer?
Check out a sample textbook solutionStudents have asked these similar questions
s
Oasis Co., a U.S. shareholder, owns 100% of Shack Co. and 100% of Studio Co., both CFCs. Shack Co. has $300,000 of gross income, of which $50,000 is effectively connected income, and $30,000 is interest expense without any allocable interest income. Shack Co. has $500,000 of machinery used in its trade or business. Studio Co. has a $150,000 loss and machinery worth $1,000,000 used in its operations.
a. What is GILTI for Oasis Co.?
(fill in the blank)
b. What impact do the operations of Shack Co. and Studio Co. have on Oasis Co.’s U.S. taxable income?
Oasis must include $fill in the blank 2 of GILTI in its U.S. taxable income, but will also get a deduction for 50% of its GILTI inclusion. As a result, its taxable income will increase by (fill in the blank).
Pearl Inc. is a Canadian-controlled private corporation (CCPC) that owns 100% of the voting shares of Oyster Ltd. and 25% of the voting shares of Shell Corp. The fair market value of the Shell Corp. shares owned by Pearl Inc. is equal to 25% of the fair market value of all Shell Corp. shares. In the current year, Pearl Inc. received the following dividends:
Eligible dividends from various portfolio investments $ 7,500
Non-eligible dividends from Oyster Ltd. $30,200
Non-eligible dividends from Shell Corp. $12,750
As a result of paying the $30,200 dividend, Oyster Ltd. received a dividend refund of $7,550. Shell Corp. received no dividend refund for its dividend payment. Which of the following is the correct amount of Part…
Chapter 11 Solutions
PRINCIPLES OF TAXATION F/BUS.+INVEST.
Ch. 11 - Prob. 1QPDCh. 11 - Prob. 2QPDCh. 11 - Prob. 3QPDCh. 11 - Prob. 4QPDCh. 11 - Prob. 5QPDCh. 11 - Libretto Corporation owns a national chain of...Ch. 11 - Prob. 7QPDCh. 11 - Prob. 8QPDCh. 11 - Prob. 9QPDCh. 11 - In your own words, explain the conclusion that...
Ch. 11 - Prob. 1APCh. 11 - Prob. 2APCh. 11 - Corporation P owns 93 percent of the outstanding...Ch. 11 - This year, Napa Corporation received the following...Ch. 11 - This year, GHJ Inc. received the following...Ch. 11 - In its first year, Camco Inc. generated a 92,000...Ch. 11 - Prob. 7APCh. 11 - Prob. 8APCh. 11 - Cranberry Corporation has 3,240,000 of current...Ch. 11 - Hallick Inc. has a fiscal year ending June 30....Ch. 11 - Landover Corporation is looking for a larger...Ch. 11 - Prob. 12APCh. 11 - Prob. 13APCh. 11 - Prob. 14APCh. 11 - Prob. 15APCh. 11 - Prob. 16APCh. 11 - In each of the following cases, compute the...Ch. 11 - Prob. 18APCh. 11 - Prob. 19APCh. 11 - Jackson Corporation has accumulated minimum tax...Ch. 11 - Prob. 21APCh. 11 - Callen Inc. has accumulated minimum tax credits of...Ch. 11 - Prob. 23APCh. 11 - Prob. 24APCh. 11 - Prob. 25APCh. 11 - James, who is in the 35 percent marginal tax...Ch. 11 - Leona, whose marginal tax rate on ordinary income...Ch. 11 - Prob. 28APCh. 11 - Prob. 29APCh. 11 - Prob. 30APCh. 11 - Prob. 1IRPCh. 11 - Prob. 2IRPCh. 11 - Prob. 3IRPCh. 11 - Prob. 4IRPCh. 11 - Prob. 5IRPCh. 11 - Prob. 6IRPCh. 11 - Prob. 7IRPCh. 11 - Prob. 8IRPCh. 11 - Prob. 1RPCh. 11 - Prob. 2RPCh. 11 - Prob. 3RPCh. 11 - This year, Prewer Inc. received a 160,000 dividend...Ch. 11 - Prob. 1TPCCh. 11 - Prob. 2TPC
Knowledge Booster
Similar questions
- Smart Ltd., a Canadian private corporation, owns 30% of the voting shares of Arch Ltd. In the current year, Arch Ltd. paid an eligible dividend of $120,000, which triggered a dividend refund of $45,000 to Arch Ltd. Smart Ltd. also received a non-eligible dividends of $70,000 from its wholly-owned subsidiary, Magna Ltd., and non-eligible dividends of $50,000 from two Canadian public corporations in which Smart Ltd. owns less than 1% of the issued shares. Magna Ltd. carries on an active business and, thus, did not receive a dividend refund. Determine the refundable Part IV tax payable by Smart Ltd. for the current year.arrow_forwardABC co. is a Canadian controlled private corporation that acquired 100% of the shares of XYZ Co. in Year 1 for $50,000. New Co., an arm's length corporation, is now interested in purchasing ABC Co.'s investment in XYZ Co.'s shares are currently worth $400,000 and the retained earnings of the company are $100,000. To reduce the fair market value of the shares, XYZ Co. will pay a dividend of $350,000 to ABC Co. and ABC Co. will then sell the shares to New Co. for $50,000 XYZ Co.'s RDTOH balances are nil. Applying the anti-avoidance rules of Subsection 55(2), what is the tax effect of the $350,000 dividend?arrow_forwardSam owns all of the shares of X Ltd. Sofia owns all of the shares of Y Ltd. The owners plan to combine their businesses by amalgamating the two corporations on September 1st of the current year. The shares of X have an ACB of $2,000 and are currently worth $100,000. The shares of Y have an ACB of $4,000 and are currently worth $130,000. X and Y are both Canadian corporations and have a December 31 taxation year-end. What is the ACB of the shares of the amalgamated corporation received by Sam? $arrow_forward
- Valley View Inc., a U.S. corporation, formed a wholly owned Mexican corporation to conduct manufacturing and selling operations in Mexico. In its first year of operations, the Mexican corporation reported taxable income of Mex$5,000,000 and paid Mexican income tax of Mex$1,500,000 on its taxable income. In the second year of its operations, the Mexican subsidiary pays a dividend of Mex$2.000,000 to Valley View, Inc. The dividend is subject to a 10 percent withholding tax (Mex$200,000) under the U.S.-Mexico treaty. Assume the currency translation rate for both years is Mex$1:US$0.05.b-1. How much of the dividend from the Mexican subsidiary is subject to U.S. taxation?b-2. Are any of the Mexican taxes imposed on the income distributed creditable to the U.S.?arrow_forwardValley View Incorporated, a U.S. corporation, formed a wholly owned Mexican corporation to conduct manufacturing and selling operations in Mexico. In its first year of operations, the Mexican corporation reported taxable income of Mex$5,000,000 and paid Mexican income tax of Mex$1,500,000 on its taxable income. In the second year of its operations, the Mexican subsidiary pays a dividend of Mex$2,000,000 to Valley View, Incorporated. The dividend is subject to a 10 percent withholding tax (Mex$200,000) under the U.S.-Mexico treaty. Assume the currency translation rate for both years is Mex$1:US$0.05. Required: a. Assuming that Valley View Incorporated's Mexican subsidiary does not have any subpart F income or global intangible low-tax income (GILTI), how much taxable income would Valley View, Incorporated, report in U.S. dollars from its Mexican subsidiary's first year of operations? b-1. How much of the dividend from the Mexican subsidiary is subject to U.S. taxation? b-2. Are any of…arrow_forwardUSCO owns 100 percent of the following corporations: Dutch N.V., Germany A.G., Australia PLC, Japan Corporation, and Brazil S.A. During the year, the following transactions took place: Determine whether these transactions result in Subpart F income. Required: a. Germany A.G. owns an office building that it leases to unrelated persons. Germany A.G. engaged an independent managing agent to manage and maintain the office building and performs no activities with respect to the property. b. Dutch N.V. leased office machines to unrelated persons. Dutch N.V. performed only incidental activities and incurred nominal expenses in leasing and servicing the machines. Dutch N.V. is not engaged in the manufacture or production of the machines and does not add substantial value to the machines. c. Dutch N.V. purchased goods manufactured in France from an unrelated contract manufacturer and sold them to Germany A.G. for consumption in Germany. d. Australia PLC purchased goods manufactured in Australia…arrow_forward
- Quantro Enterprises Ltd. and Baizley Holdings Ltd. (BHL) are both 100% owned by Harold Baizley. Both companies are Canadian- controlled private corporations. Quantro operates a wholesale business and pays rent to BHL for the use of a warehouse property. BHL owns only one asset-the warehouse building and related land that is rented by Quantro for $36,000 per year. The property was originally owned by Quantro but was sold to BHL several years ago as a means to reduce the risk exposure of this appreciating asset. On December 31, 2023 (the year-end of both companies), BHL sold the warehouse property to a third party for $370,000 (land $40,000, building $330,000). The property originally cost $320,000 (land $25,000, building $295,000). The undepreciated capital cost of the building at December 31, 2022, was $254,000. One month before selling the warehouse property, BHL purchased a newly constructed warehouse property for $480,000. (land $50,000, building $430,000.). Required: Determine…arrow_forwardJan is the sole shareholder of Jan Ltd. Summer is the sole shareholder of SKY Co. Both of the companies are CCPCs. Jan and Summer will amalgamate their corporations as per Section 87(1) on July 21st, forming JS Ltd. Jan's shares in Jan Ltd. have an ACB of $1,000 and a fair market value of $24,500. Summer's shares in SKY Co. have an ACB of $1,500 and a fair market value of $45,500. Which of the following will apply with respect to the planned amalgamation? Multiple Choice The ACB of Jan's and Summer's shares in JS Ltd. will be $24,500 and $45,500, respectively. JS Ltd.'s first taxation year will commence on July 22ndarrow_forwardTenco. a U.S. corporation. manutactures tennis rackets tor sale in the United States and abroad. Tenco owns 100% of the stock of Teny. a foreign sales subsidiary that was organized in Year 1. During Year 1. Ten had $15 million of foreign base company sales income, paid $1 million in foreign income taxes and distributed no dividends During Year 2, Teny had no earnings and profits, paid no foreign income taxes and distributed a $14 million dividend. Assuming the U.S. cornorate tax rate is 21%. what are the U.S. tax consequences of Teny's Year1 and Year 2 activities?arrow_forward
- Hart Enterprises, a U.S. corporation, owns 100% of OK, Ltd., an Irish corporation. OK's gross income for the year is $10,000,000. Determine OK's Subpart F income (before any expenses) from the transactions that it reported this year. If an amount is zero, enter "0". Transaction Income Includedin Subpart F a. OK received $600,000 from sales of products purchased from Hart and sold to customers outside Ireland. $ b. OK received $1,000,000 from sales of products purchased from Hart and sold to customers in Ireland. $ c. OK received $400,000 from sales of products purchased from unrelated suppliers and sold to customers in Germany. $ d. OK purchased raw materials from Hart, used these materials to manufacture finished goods, and sold these goods to customers in Italy. OK earned $300,000 from these sales. $ e. OK received $100,000 for the performance of warranty services on behalf of Hart. These services were performed in Japan for customers located in Japan. $…arrow_forwardSwanson Ltd. holds 15% of the common shares of Virginia Inc. Swanson is able to appoint three members of Virginia’s 12-member board of directors and is a supplier of raw materials to Virginia. The remaining 85% of Virginia’s common shares are widely held. Virginia is a private company. Assuming that Swanson reports under ASPE, what are the reporting options for its investment in Virginia? Question 4 options: a) Swanson must use the fair value method. b) Swanson must use the consolidation method. c) Swanson can use the cost or fair value method. d) Swanson can use the cost or equity method.arrow_forwardPalm owns a 70% interest in Sable, a domestic subsidiary. Sable is not part of Palm's affiliated group. Palm will pay taxes on Select one: a. 80% of the dividends it receives from Sable. b. 66% of the dividends it receives from Sable. c. none of the dividends it receives from Sable. d. 20% of the dividends it receives from Sable.arrow_forward
arrow_back_ios
SEE MORE QUESTIONS
arrow_forward_ios
Recommended textbooks for you