Paton Corporation, a U.S. corporation, owns 100% of the stock of Tappan Ltd, a British corporation, and

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Paton Corporation, a U.S. corporation, owns 100% of the stock of Tappan Ltd, a British corporation, and 100% of the stock of Monroe N.V., a Dutch corporation. Monroe has post-1986 undistributed earnings of €600 and post-1986 foreign income taxes of $400. Tappan has post-1986 undistributed earnings of £800 and post-1986 foreign income taxes of $200. During the current year, Tappan paid Paton a dividend of £100 and Monroe paid Paton a dividend of €100. The dividends were exempt from withholding tax under the U.S.-UK and U.S.-Netherlands income tax treaties. The exchange rates are as follows: €1:$1.50 and£1:$2.00.

a. Compute Paton's deemed paid credit on the dividends it received from Tappan and Monroe.

b. Assume this is Paton's only income and compute the company's net U.S. tax after allowance of any foreign tax credits.

Dividend
A dividend is a distribution of a portion of company’s earnings, decided and managed by the company’s board of directors, and paid to the shareholders. Dividends are given on the shares. It is a token reward paid to the shareholders for their...
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Taxation Of Individuals And Business Entities 2015

ISBN: 9780077862367

6th Edition

Authors: Brian Spilker, Benjamin Ayers, John Robinson, Edmund Outslay, Ronald Worsham, John Barrick, Connie Weaver

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