PRINCIPLES OF TAXATION F/BUS...(LL)
23rd Edition
ISBN: 9781260433197
Author: Jones
Publisher: MCG
expand_more
expand_more
format_list_bulleted
Question
Chapter 11, Problem 2AP
To determine
Identify the corporations which forms an affiliated group eligible to file a consolidated tax return.
Expert Solution & Answer
Want to see the full answer?
Check out a sample textbook solution
Students have asked these similar questions
Oasis Co., a U.S. shareholder, owns 100% of Shack Co. and 100% of Studio Co., both CFCs. Shack Co. has $300,000 of gross income, of which $50,000 is effectively connected income, and $30,000 is interest expense without any allocable interest income. Shack Co. has $500,000 of machinery used in its trade or business. Studio Co. has a $150,000 loss and machinery worth $1,000,000 used in its operations.
a. What is GILTI for Oasis Co.?
(fill in the blank)
b. What impact do the operations of Shack Co. and Studio Co. have on Oasis Co.’s U.S. taxable income?
Oasis must include $fill in the blank 2 of GILTI in its U.S. taxable income, but will also get a deduction for 50% of its GILTI inclusion. As a result, its taxable income will increase by (fill in the blank).
Pearl Inc. is a Canadian-controlled private corporation (CCPC) that owns 100% of the voting shares of Oyster Ltd. and 25% of the voting shares of Shell Corp. The fair market value of the Shell Corp. shares owned by Pearl Inc. is equal to 25% of the fair market value of all Shell Corp. shares. In the current year, Pearl Inc. received the following dividends:
Eligible dividends from various portfolio investments $ 7,500
Non-eligible dividends from Oyster Ltd. $30,200
Non-eligible dividends from Shell Corp. $12,750
As a result of paying the $30,200 dividend, Oyster Ltd. received a dividend refund of $7,550. Shell Corp. received no dividend refund for its dividend payment. Which of the following is the correct amount of Part…
ABC co. is a Canadian controlled private corporation that acquired 100% of the shares of XYZ Co. in Year 1 for $50,000. New Co., an arm's length corporation, is now interested in purchasing ABC Co.'s investment in XYZ Co.'s shares are currently worth $400,000 and the retained earnings of the company are $100,000. To reduce the fair market value of the shares, XYZ Co. will pay a dividend of $350,000 to ABC Co. and ABC Co. will then sell the shares to New Co. for $50,000 XYZ Co.'s RDTOH balances are nil. Applying the anti-avoidance rules of Subsection 55(2), what is the tax effect of the $350,000 dividend?
Chapter 11 Solutions
PRINCIPLES OF TAXATION F/BUS...(LL)
Ch. 11 - Prob. 1QPDCh. 11 - Prob. 2QPDCh. 11 - Prob. 3QPDCh. 11 - Prob. 4QPDCh. 11 - Prob. 5QPDCh. 11 - Libretto Corporation owns a national chain of...Ch. 11 - Prob. 7QPDCh. 11 - Prob. 8QPDCh. 11 - Prob. 9QPDCh. 11 - In your own words, explain the conclusion that...
Ch. 11 - Prob. 1APCh. 11 - Prob. 2APCh. 11 - Corporation P owns 93 percent of the outstanding...Ch. 11 - This year, Napa Corporation received the following...Ch. 11 - This year, GHJ Inc. received the following...Ch. 11 - In its first year, Camco Inc. generated a 92,000...Ch. 11 - Prob. 7APCh. 11 - Prob. 8APCh. 11 - Cranberry Corporation has 3,240,000 of current...Ch. 11 - Hallick Inc. has a fiscal year ending June 30....Ch. 11 - Landover Corporation is looking for a larger...Ch. 11 - Cramer Corporation, a calendar year, accrual basis...Ch. 11 - Prob. 13APCh. 11 - Prob. 14APCh. 11 - Prob. 15APCh. 11 - Prob. 16APCh. 11 - In each of the following cases, compute the...Ch. 11 - Prob. 18APCh. 11 - Prob. 19APCh. 11 - Jackson Corporation has accumulated minimum tax...Ch. 11 - Camden Corporation, a calendar year accrual basis...Ch. 11 - Callen Inc. has accumulated minimum tax credits of...Ch. 11 - Prob. 23APCh. 11 - Prob. 24APCh. 11 - In 2018, NB Inc.s federal taxable income was...Ch. 11 - James, who is in the 35 percent marginal tax...Ch. 11 - Leona, whose marginal tax rate on ordinary income...Ch. 11 - Prob. 28APCh. 11 - Prob. 29APCh. 11 - Prob. 30APCh. 11 - Prob. 1IRPCh. 11 - Prob. 2IRPCh. 11 - Prob. 3IRPCh. 11 - Prob. 4IRPCh. 11 - Prob. 5IRPCh. 11 - Prob. 6IRPCh. 11 - Prob. 7IRPCh. 11 - Prob. 8IRPCh. 11 - Prob. 1RPCh. 11 - Prob. 2RPCh. 11 - Prob. 3RPCh. 11 - This year, Prewer Inc. received a 160,000 dividend...Ch. 11 - Prob. 1TPCCh. 11 - Prob. 2TPC
Knowledge Booster
Similar questions
- Valley View Inc., a U.S. corporation, formed a wholly owned Mexican corporation to conduct manufacturing and selling operations in Mexico. In its first year of operations, the Mexican corporation reported taxable income of Mex$5,000,000 and paid Mexican income tax of Mex$1,500,000 on its taxable income. In the second year of its operations, the Mexican subsidiary pays a dividend of Mex$2.000,000 to Valley View, Inc. The dividend is subject to a 10 percent withholding tax (Mex$200,000) under the U.S.-Mexico treaty. Assume the currency translation rate for both years is Mex$1:US$0.05.b-1. How much of the dividend from the Mexican subsidiary is subject to U.S. taxation?b-2. Are any of the Mexican taxes imposed on the income distributed creditable to the U.S.?arrow_forwardUSCO owns 100 percent of the following corporations: Dutch N.V., Germany A.G., Australia PLC, Japan Corporation, and Brazil S.A. During the year, the following transactions took place: Determine whether these transactions result in Subpart F income. Required: a. Germany A.G. owns an office building that it leases to unrelated persons. Germany A.G. engaged an independent managing agent to manage and maintain the office building and performs no activities with respect to the property. b. Dutch N.V. leased office machines to unrelated persons. Dutch N.V. performed only incidental activities and incurred nominal expenses in leasing and servicing the machines. Dutch N.V. is not engaged in the manufacture or production of the machines and does not add substantial value to the machines. c. Dutch N.V. purchased goods manufactured in France from an unrelated contract manufacturer and sold them to Germany A.G. for consumption in Germany. d. Australia PLC purchased goods manufactured in Australia…arrow_forwardValley View Incorporated, a U.S. corporation, formed a wholly owned Mexican corporation to conduct manufacturing and selling operations in Mexico. In its first year of operations, the Mexican corporation reported taxable income of Mex$5,000,000 and paid Mexican income tax of Mex$1,500,000 on its taxable income. In the second year of its operations, the Mexican subsidiary pays a dividend of Mex$2,000,000 to Valley View, Incorporated. The dividend is subject to a 10 percent withholding tax (Mex$200,000) under the U.S.-Mexico treaty. Assume the currency translation rate for both years is Mex$1:US$0.05. Required: a. Assuming that Valley View Incorporated's Mexican subsidiary does not have any subpart F income or global intangible low-tax income (GILTI), how much taxable income would Valley View, Incorporated, report in U.S. dollars from its Mexican subsidiary's first year of operations? b-1. How much of the dividend from the Mexican subsidiary is subject to U.S. taxation? b-2. Are any of…arrow_forward
- Indigo Inc. is a large multinational corporation with a number of subsidiaries located in countries all over the world. One of Indigo's subsidiaries, Sweet Ltd., sold a piece of manufacturing equipment to another one of Indigo's subsidiaries, Pharoah Inc. Indigo owned 80% of Sweet and 65% of Pharoah. The equipment had been on Sweet's books at a carrying value of $128,000, and had a fair market value of $153,850. Pharoah paid $132,800 for the equipment. Both Sweet and Pharoah were in the business of selling manufactured products to their customers; the sale of the equipment was considered to be outside the normal course of both businesses. Identify what value should be used by both Sweet and Pharoah to record the sale/purchase of the equipment. Sweet to record the sale/purchase of the equipment at $4 Pharoah to record the sale/purchase of the equipment at 2$arrow_forwardTenco. a U.S. corporation. manutactures tennis rackets tor sale in the United States and abroad. Tenco owns 100% of the stock of Teny. a foreign sales subsidiary that was organized in Year 1. During Year 1. Ten had $15 million of foreign base company sales income, paid $1 million in foreign income taxes and distributed no dividends During Year 2, Teny had no earnings and profits, paid no foreign income taxes and distributed a $14 million dividend. Assuming the U.S. cornorate tax rate is 21%. what are the U.S. tax consequences of Teny's Year1 and Year 2 activities?arrow_forwardHart Enterprises, a U.S. corporation, owns 100% of OK, Ltd., an Irish corporation. OK's gross income for the year is $10,000,000. Determine OK's Subpart F income (before any expenses) from the transactions that it reported this year. If an amount is zero, enter "0". Transaction Income Includedin Subpart F a. OK received $600,000 from sales of products purchased from Hart and sold to customers outside Ireland. $ b. OK received $1,000,000 from sales of products purchased from Hart and sold to customers in Ireland. $ c. OK received $400,000 from sales of products purchased from unrelated suppliers and sold to customers in Germany. $ d. OK purchased raw materials from Hart, used these materials to manufacture finished goods, and sold these goods to customers in Italy. OK earned $300,000 from these sales. $ e. OK received $100,000 for the performance of warranty services on behalf of Hart. These services were performed in Japan for customers located in Japan. $…arrow_forward
- Palm owns a 70% interest in Sable, a domestic subsidiary. Sable is not part of Palm's affiliated group. Palm will pay taxes on Select one: a. 80% of the dividends it receives from Sable. b. 66% of the dividends it receives from Sable. c. none of the dividends it receives from Sable. d. 20% of the dividends it receives from Sable.arrow_forwardSwanson Ltd. holds 15% of the common shares of Virginia Inc. Swanson is able to appoint three members of Virginia’s 12-member board of directors and is a supplier of raw materials to Virginia. The remaining 85% of Virginia’s common shares are widely held. Virginia is a private company. Assuming that Swanson reports under ASPE, what are the reporting options for its investment in Virginia? Question 4 options: a) Swanson must use the fair value method. b) Swanson must use the consolidation method. c) Swanson can use the cost or fair value method. d) Swanson can use the cost or equity method.arrow_forwardRose plc has two shareholders: · Investor A plc owns 60% of Rose plc’s ordinary shares and voting rights; · Investor B plc owns the remaining 40%. Rose plc’s articles of association stipulate that at least 80% of the voting rights are required to make decisions about Rose’s relevant activities. Rose plc does not depend on its shareholders for settling its liabilities and no shareholder has contractual rights or obligations to the individual assets nor liabilities of Rose plc. How should the investment in Rose plc be consolidated in Investor A plc’s group financial statements according to IFRS? a. As a subsidiary b. As an associate c. As a joint venture d. As a joint operation e. As a liabilityarrow_forward
- Melissa Corporation is domiciled in Germany and is listed on both the Frankfurt and New York Stock Exchanges. Melissa has chosen to prepare consolidated financial statements in accordance with U.S. GAAP for filing with the U.S. Securities and Exchange Commission but must also prepare consolidated financial statements in accordance with IFRS in accordance with European Union regulations. On December 31, 20X0, Melissa Corporation purchased a small office building for $1,380,000. For tax and financial reporting purposes, Melissa estimates that the building has a useful life of 40 years with an estimated residual value of $100,000. Melissa uses straight-line depreciation for financial reporting. Assume that, for tax purposes, Melissa is permitted to deduct 5% of an asset’s depreciable base in 20X1. This is the only building that Melissa owns. At the end of 20X1, Melissa had the building appraised by a qualified real estate appraiser, who estimated the fair value of the building to be…arrow_forwardMelissa Corporation is domiciled in Germany and is listed on both the Frankfurt and New York Stock Exchanges. Melissa has chosen to prepare consolidated financial statements in accordance with U.S. GAAP for filing with the U.S. Securities and Exchange Commission but must also prepare consolidated financial statements in accordance with IFRS in accordance with European Union regulations. On December 31, 20X0, Melissa Corporation purchased a small office building for $1,380,000. For tax and financial reporting purposes, Melissa estimates that the building has a useful life of 40 years with an estimated residual value of $100,000. Melissa uses straight-line depreciation for financial reporting. Assume that, for tax purposes, Melissa is permitted to deduct 5% of an asset's depreciable base in 20X1. This is the only building that Melissa owns. At the end of 20X1, Melissa had the building appraised by a qualified real estate appraiser, who estimated the fair value of the building to be…arrow_forwardUnited States Tool Corp., a U.S. corporation, sells all of the stock of its wholly owned German Subsidiary, Modern Tool A.G., to an unrelated German corporation for $50 million cash, which produces a gain of $40 million. All negotiations occur and the sale contract is executed in Germany. Title to the stock passes to the purchaser in Germany, and the purchase price is paid in Germany. Modern Tool A.G. has been actively engaged in business in Germany and France for the last 10 years and has received approximately 60 percent of its gross income from France and 40 percent from Germany each year. Is the gain foreign-source income?arrow_forward
arrow_back_ios
SEE MORE QUESTIONS
arrow_forward_ios
Recommended textbooks for you
