Question 22

LO.3, 6 Determine whether the sourcing of income in each of the following situations is U.S. or foreign. a. USCO sells depreciable personal property (produced in the United States) that it has been using in its foreign branch operations. The property sells for $180,000, has a tax basis of $75,000, and has been depreciated for tax purposes to the extent of $90,000. The property is located in a foreign country but is sold to another domestic corporation. The sales transaction takes place in the United States. b. Jacques, an NRA, sells an apartment building to Julie, a U.S. resident, at a $200,000 gain. The building is located in Denver. The closing takes place in Jacques's country of residence. C. Carla, an NRA, is an employee of a non-U.S. corporation. During the tax year, she spends 80 days in the United States purchasing cloth for her employer, a clothing manufacturer. Her yearly salary is $150,000 (translated into U.S. dollars). Carla spends a total of 200 days working during the…

A non-U.S. corporation investor held a real estate asset (a parcel of land) that that was purchased for $100,000,000 for 10 years and will sell it for $130,000,000. The investor gain on the sale of the asset is considered to in a business that is effectively connected to a U.S. trade or business (ECI). a. Compute the tax on the sale assuming that the investor held the asset directly (consider both ECI and branch profits tax) b. Compute the tax to the investor if held through US corporation (consider both entity level tax and FDAP tax on the distributions) with no treaty rates and a plan of liquidation in the year of sale USE IRS,USA AND CPA REGULATIONS

A non-U.S. corporation investor held a real estate asset (a parcel of land) that that was purchased for $100,000,000 for 10 years and will sell it for $130,000,000. The investor gain on the sale of the asset is considered to in a business that is effectively connected to a U.S. trade or business (ECI).   Compute the tax on the sale assuming that the investor held the asset directly (consider double tax - both ECI and branch profits tax) __________________   Compute the tax to the investor if held through US corporation (consider both entity level tax and FDAP tax on the distributions) with no treaty rates and a plan of liquidation in the year of sale _______________________

Which is a correct statement?   Domestic corporations shall elect either MCIT or RCIT. Resident foreign corporations are liable to either 20% or 25% RCIT. MSMEs may still be taxable like large corporations. Resident foreign corporations are elect either RCIT and MCIT.     2. TRUE or FALSE: Interest expenses are deductible in full amount if there is no interest income subject to final tax during the period.

1 canadian taxation-2 Which of the following scenarios would be most appropriate for a Section 85 rollover?     A shareholder of a corporation wishes to transfer property with a fair market value of $150,000 and a tax cost of $100,000 to his corporation.     A shareholder of a corporation wishes to transfer property with a fair market value of $100,000 and a tax cost of $150,000 to his corporation.     A shareholder of a corporation wishes to transfer property with a fair market value of $150,000 and a tax cost of $100,000 from his corporation.     A shareholder of a corporation wishes to transfer property with a fair market value of $100,000 and a tax cost of $150,000 from his corporation.

Statement 1: When a taxpayer receives a car from a corporation for furnishing the names of potential customers, the same is a taxable income. Statement 2: When a foreign corporation “donates” stocks to its resident manager in the Philippines in consideration of his services as such, the value of the shares shall be considered as taxable compensation.  a. Both statements are true b. Both statements are false c. Only statement 1 is true d. Only statement 2 is true

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.

Which of the following statements with respect to the taxation of capital gains is not correct?     A. When government assistance is provided to acquire a capital asset, it is deducted from the adjusted cost base of the asset.   B. Gains resulting from dispositions of personal use capital assets are subject to tax.   C. When an individual sells shares in a Canadian small business corporation, any resulting capital gain can be deferred if the proceeds are reinvested in shares of another Canadian small business corporation.   D. When a part of a group of identical securities is sold, the adjusted cost base of the shares sold must be based on the average cost of the group.

This is about tax in the Caribbean can you help please. iii. Calculate the Corporation Tax Liability of Full  Co. for Y/A: 20212. Using the Barbados Income Tax Act or any other relevant document explain the treatment of theitems included or omitted from the income tax computation.

Dividend income received by a domestic corporation from a nonresident foreign corporation may be exempt from income tax, provided: The dividends actually received or remitted into the Philippines are reinvested in the business operations of the domestic corporation within the next taxable year from the time the foreign-source dividends were received or remitted; The dividends received shall only be used to fund the working capital requirements, capital expenditures, dividend payments, investment in domestic subsidiaries, and infrastructure project; and a. b. C. d. The domestic corporation holds directly at least twenty percent (20%) in value of the outstanding shares of the foreign corporation and has held the shareholdings uninterruptedly for a minimum of two (2) years at the time of the dividends distribution. In case the foreign corporation has been in existence for less than two (2) years at the time of dividends distribution, then the domestic corporation must have continuously…

Which of the following is true?  Non-profit corporations are exempt from corporate income tax. Domestic corporations shall choose ether MCIT or RCIT. Whenever MCIT is payable, there is a Net Operating Loss Carry-Over. MCIT does not apply to foreign corporations.

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.?

a. Both statements are true b. Both statements are false c. Only statement 1 is true d. Only statement 2 is true

Zenon, Incorporated has the following taxable income: U.S. source income Foreign source income Taxable income $ 1,900,000 240,000 $ 2,140,000 Required: Zenon paid $33,000 foreign income tax. Compute its U.S. income tax, if Zenon conducted its foreign operations through a foreign subsidiary that made no shareholder distributions during the current year and had no GILTI or subpart F income. U.S. income tax

A U.S. tax-exempt entity investor held a real estate asset (a parcel of land) that that was purchased for $50,000,000, was held for 10 years, and will now be sold for $90,000,000.  At the time of the sale, there was $5,000,000 outstanding on the loan that was used to acquire the land (ignore interest accruals or payments of any kind for this question).   Compute the tax on the sale assuming that the investor was a pension plan (a qualified organization) and held the asset directly __________________   Compute the tax on the sale assuming that the investor was a private foundation (a non-qualified organization) and held the asset directly __________________   Compute the tax on the sale assuming that the investor was a pension plan (a qualified organization) and held the asset through a partnership that violated the fractions rule __________________   Compute the tax to the investor if held the asset through a corporation (consider both entity tax and tax on the distributions)…

U.S. corporations are eligible for a foreign tax credit for withholding taxes imposed on dividends received from 100 percent owned foreign corporations, even if the dividend qualifies for the 100 percent dividends received deduction.  True or False

Ranger Company located business in two jurisdications, Singapore and Malaysia. In both countries, the entity has the legal right to offset the taxes receivable and payable. The following information related to deferred taxe assets and liabilities: Classification                   Amount            Taxing jurisdiction Deferred tax asset         800,000                   Singapore Deferred tax liability     300,000                   Malaysia Deefrred tax liability     600,000                   Singapore Required:  How should the entity present deferred taxes at year- end?    Defferd tax asset         Deferred tax liability a.  800,000                       900,000 b.   0                                 1,000,000 c.   200,000                        600,000 d.  200,000                     300,000

A Canadian corporation's net income for tax purposes may be reduced by which of the following to arrive at taxable income? a. Dividends received from other taxable Canadian corporations b. Interest received from other taxable Canadian corporations c. Rental income received from other taxable Canadian corporations d. Royalty received from other taxable Canadian corporations

In order to simplify the tax code, current regulations require that a dollar of income earned by a U.S. Corporation in the United States is taxed in the same way as a dollar of income earned by a U.S. Corporation in a foreign country.    Select one: True False