Partin, Inc., a foreign subsidiary of Jones, Inc., a U.S. corporation, has pretax income of 200,000 euros

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Partin, Inc., a foreign subsidiary of Jones, Inc., a U.S. corporation, has pretax income of 200,000 euros for 2014. Partin accrues 60,000 euros in foreign taxes on this income. The average exchange rate for the tax year to which the taxes relate is 1.35€:$1. None of the income is Subpart F income. If the net earnings of 140,000 euros are distributed when the exchange rate is 1.25€:$1, what are the deemed-paid taxes available to Jones? Assume that 2014 is Partin's first year of operation.
Exchange Rate
The value of one currency for the purpose of conversion to another. Exchange Rate means on any day, for purposes of determining the Dollar Equivalent of any currency other than Dollars, the rate at which such currency may be exchanged into Dollars...
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South Western Federal Taxation 2014 Comprehensive Volume

ISBN: 9781285180922

37th Edition

Authors: William H. Hoffman, David M. Maloney, William A. Raabe, James C. Young

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