Engco, a U.S. corporation, produces industrial engines at its U.S. plant for sale in the United States and Canada. During the current year, Engco's total sales to Canadian customers are $10 million and the related cost of goods sold is $7 million. Title passes in Canada on all engine sales to Canadian customers
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Engco, a U.S. corporation, produces industrial engines at its U.S. plant for sale in the United States and Canada. During the current year, Engco's total sales to Canadian customers are $10 million and the related cost of goods sold is $7 million. Title passes in Canada on all engine sales to Canadian customers
a. How much of Engco's export gross profit of $3 million (export sales of $10 million less
$7 million cost of goods sold) is classified as foreign-source tor U.S. tax purposes?
b. Now assume that the facts are the same as in part (a), except that EngCo is a distributor that purchases the ensines trom indevendent third parties tor sale to customers in both the United States and Canada. How much of Engco's export gross profit of $3 million from Canadian sales is classitied as foreign-source tor U.S. tax purposes?
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- WISsub annually resells to industrial manufacturing companies approximately 30,000 industrial ovens purchased from FORCo, its foreign parent, that are neither branded nor warranted. FORCo also sells 5,000 industrial ovens to an independent third party in Canada for $100,000 each. Unlike the industrial ovens sold to WISsub, the industrial ovens sold in Canada are warranted and bear the valuable FORCo label. Suppose that the comparable profits methodology is the best method. Further assume that your search for comparable companies preliminarily includes those on the list below with all return on sales figures being a proper average of the last three taxable years. Which of the companies are functionally comparable to WISsub? (a)a) Mashimoto Electric is based in Osaka, Japan. Mashimoto Electric has a subsidiary inSingapore that generates SGD 50 million in annual sales. Any earnings generated by thesubsidiary are reinvested to support its operations. Benzai Electric is the close competitor ofMashimoto Electric. Benzai Electric is a local Japanese company located in Japan with 2 annual export sale to Singapore of about SGD 50 million. Based on the informationprovided, which firm is subject to a higher degree of translation exposure? Justify youranswer with thorough explanation on both companies.b) Diamond Limited, a New Zealand company has an Australian subsidiary that earnedAUD40 million this year. Little Limited, which is also resided in New Zealand has anAustralian subsidiary that earned AUD30 million this year. The subsidiary of DiamondLimited plans to reinvest its earnings in Australia while the subsidiary of Little Limitedplans to remit its earnings to the New Zealand parent. Another New Zealand…BIC Co. is residing in Spain and exports bottles of wine in its Mexican Market for 225 Mexican Peso each bottle which costs BIC Co. 50 Pounds from wine distillery in United Kingdom. Exchange rates identified are the following for June 10, 2022:· 1 Euro = 15 Mexican Peso = 10 PoundsHow much total gross profit in Euro doesBIC Co. made for June 10, 2022 considering the firm exported 3,000 wine bottles?
