orldwide income of $150,000, including a foreign branch limitation loss of ($100,000), a foreign branch limitation income of $50,000 (on which USAco paid $12,500 in foreign taxes), $100,000 of passive limitation income (on which USAco paid $10,000 in foreign taxes), and $100,000 of U.S.-source income. In year 2, USAco has worldwide income of $275,000, including $75,000 of foreign branch limitation income, (on which USAco paid $18,750 in foreign taxes) $100,000 of passive limitation income (on which USAco paid $10,000 in foreign taxes), and $100,000 of U.S.­ source income.   What are USAco’s U.S. tax liabilities for year 1 and year 2?  Assume that the U.S.

SWFT Essntl Tax Individ/Bus Entities 2020
23rd Edition
ISBN:9780357391266
Author:Nellen
Publisher:Nellen
Chapter16: Multijurisdictional Taxation
Section: Chapter Questions
Problem 19P
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1.

In year 1, USAco has worldwide income of $150,000, including a foreign branch limitation loss of ($100,000), a foreign branch limitation income of $50,000 (on which USAco paid $12,500 in foreign taxes), $100,000 of passive limitation income (on which USAco paid $10,000 in foreign taxes), and $100,000 of U.S.-source income. In year 2, USAco has worldwide income of $275,000, including $75,000 of foreign branch limitation income, (on which USAco paid $18,750 in foreign taxes) $100,000 of passive limitation income (on which USAco paid $10,000 in foreign taxes), and $100,000 of U.S.­ source income.  

What are USAco’s U.S. tax liabilities for year 1 and year 2?  Assume that the U.S. tax rate is 21%. Show your work.

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