Horatio, a citizen and resident of Ireland, is an equal partner with Imogene, a US citizen, in a consulting firm operating out of a Miami office and serving clients located in Florida. Under the terms of the K agreement, Horatio and Imogene are to share equally in profits and losses. During the course of the year, Horatio devotes

SWFT Essntl Tax Individ/Bus Entities 2020
23rd Edition
ISBN:9780357391266
Author:Nellen
Publisher:Nellen
Chapter11: Individuals As Employees And Proprietors
Section: Chapter Questions
Problem 24P
icon
Related questions
Question

Horatio, a citizen and resident of Ireland, is an equal partner with Imogene, a US citizen, in a consulting firm operating out of a Miami office and serving clients located in Florida. Under the terms of the K agreement, Horatio and Imogene are to share equally in profits and losses. During the course of the year, Horatio devotes 100 days to the venture, but works primarily at home in Dublin and communicates with his partner and his clients by telephone, fax, and Internet. In fact, Horatio is actually in the United States only 10 days during the year. During the year, the K earns net income of $200,000, all of which derives from the provision of consulting services by the K to clients in the United States. All of the K income is reinvested in the business and none is distributed to the partners. Horatio has no other economic involvement in the United States.

 

To what extent, if at all, will Horatio be subject to US income taxes for the year?

 

 

Expert Solution
steps

Step by step

Solved in 2 steps

Blurred answer
Knowledge Booster
Foreign Earned Income
Learn more about
Need a deep-dive on the concept behind this application? Look no further. Learn more about this topic, accounting and related others by exploring similar questions and additional content below.
Similar questions
Recommended textbooks for you
SWFT Essntl Tax Individ/Bus Entities 2020
SWFT Essntl Tax Individ/Bus Entities 2020
Accounting
ISBN:
9780357391266
Author:
Nellen
Publisher:
Cengage
SWFT Comprehensive Volume 2019
SWFT Comprehensive Volume 2019
Accounting
ISBN:
9780357233306
Author:
Maloney
Publisher:
Cengage
SWFT Comprehensive Vol 2020
SWFT Comprehensive Vol 2020
Accounting
ISBN:
9780357391723
Author:
Maloney
Publisher:
Cengage
SWFT Individual Income Taxes
SWFT Individual Income Taxes
Accounting
ISBN:
9780357391365
Author:
YOUNG
Publisher:
Cengage