INTERMEDIATE ACCOUNTING
5th Edition
ISBN: 9781307352320
Author: Doupnik
Publisher: MCG
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Chapter 9, Problem 9EP
To determine
Calculate the amount of penalty for underpayment of taxes.
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Spartan Corporation, a U.S. corporation, reported $6.2 million of pretax income from its business operations in Spartania, which were conducted through a foreign branch. Spartania taxes branch income at 15 percent, and the United States taxes corporate income at 21 percent.
Required:
a. If the United States provided no mechanism for mitigating double taxation, what would be the total tax (U.S. and foreign) on the $6.2 million of branch profits?
b. Assume the United States allows U.S. corporations to exclude foreign source income from U.S. taxation. What would be the total tax on the $6.2 million of branch profits?
c. Assume the United States allows U.S. corporations to claim a deduction for foreign income taxes. What would be the total tax on the $6.2 million of branch profits?
d-1. Assume the United States allows U.S. corporations to claim a credit for foreign income taxes paid on foreign source income. What would be the total tax on the $6.2 million of branch profits?
d-2. Assume the…
Pursuant to the Foreign Account Tax Compliance Act, foreign financial institutions will have to report directly to the IRS certain information about financial accounts held by U.S. taxpayers, or by foreign entities in which U.S. taxpayers hold a substantial ownership interest. Proper compliance will require specific information intended to preclude U.S. taxpayer investors to utilize such investment vehicles to obtain potentially tax-exempt benefits intended for foreign taxpayers. Failure to properly comply will result in a 30% withholding tax with respect to payments flowing outside the U.S.
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True
False
New America, Inc., a USA exporter of computer hardware intends to open a retail subsidiary in Kabul, Afghanistan sometime during tax year 2019. New America’s chief accountant has contacted our firm to inquire about income taxation for this planned business in Afghanistan and about the income tax obligations they might incur if they followed through with their plan. They also have asked to compare the Afghanistan tax rates and the rules governing ordinary and necessary business deductions to the respective US tax provisions.
set up the memorandum. Conduct appropriate research and cite all relevant primary authority (tax code, regulations, etc.).
Chapter 9 Solutions
INTERMEDIATE ACCOUNTING
Ch. 9 - Prob. 1QCh. 9 - Prob. 2QCh. 9 - 3. What is the performance evaluation objective of...Ch. 9 - 4. Why is there often a conflict between the...Ch. 9 - 5. How can transfer pricing be used to reduce the...Ch. 9 - Prob. 6QCh. 9 - 7. What is the arm’s-length range of transfer...Ch. 9 - Prob. 8QCh. 9 - 9. What is an advance pricing agreement?
Ch. 9 - 10. What are the costs and benefits associated...
Ch. 9 - Prob. 1EPCh. 9 - Prob. 2EPCh. 9 - Prob. 3EPCh. 9 - Prob. 4EPCh. 9 - 5. Which of the following is not a method commonly...Ch. 9 - Prob. 6EPCh. 9 - Prob. 7EPCh. 9 - Prob. 8EPCh. 9 - Prob. 9EPCh. 9 - Prob. 10EPCh. 9 - Prob. 11EPCh. 9 - Prob. 12EPCh. 9 - Prob. 13EPCh. 9 - 14. Superior Brakes Corporation manufactures truck...Ch. 9 - Prob. 15EPCh. 9 - Prob. 16EPCh. 9 - Prob. 18EPCh. 9 - Prob. 20EP
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