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 _______________________
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 _______________________
Chapter15: Choice Of Business Entity—other Considerations
Section: Chapter Questions
Problem 81P
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- 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
_______________________
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