Question
1. A U.S. based taxpayer has a CFC, which it considers to be permanently reinvested. the CFC has a 10,000 U.S. dollars permanent add back
1. A U.S. based taxpayer has a CFC, which it considers to be permanently reinvested. the CFC has a 10,000 U.S. dollars permanent add back for penalties. what is the amount that will be included in the rate rec for penalties? The US tax rate is 25% and the foreign tax rate is 15%.
2. Taxpayer acquired an entity in which tax deductible goodwill was created. The book basis of the goodwill is $8,000 and the tax basis of the goodwill is $5,000 . The rate rate is 25%. What is the DTA and DTL that is recorded as a result of this basis.
3. Taxpayer acquired an entity in a nontaxable business combination and the preliminary goodwill recorded for book purposes is $100,000. Accounts receivables is the only asset acquired that had a different fair value ($35,000) and tax basis ($15,000). Tax rate is 25%. What is the final goodwill that will be recorded?
4. Taxpayer acquired an entity for $300,000 that is recorded as an asset acquisition for U.S. GAAP (and not a business combination). The entity's only assets with no tax basis. Tax rate is 25%. What is the U.S. GAAP basis that the fixed assets are recorded at?
5. A taxpayer is headquartered in the U.S. and operates as a CFC in Panama. The company's position is that they are permanently reinvested under APB 23. THE U.S. Tax Rate is 35% and the Panama tax rate is 5%. The requirements to this problem are:
i. Calculate a book to tax by country.
ii. Show the journal entry to record the provision under ASC 740 by country.
iii. Calculate the rate reconciliation by county.
U.S. Panama
PTBI 800,000 50,000
Unfavorable permanent difference 80,000 5,000
Favorable permanent difference 72,000 4,500
Favorable temporary difference 250,000 500
Nonrefundable temporary difference 10,000 25,000
Nonrefundable tax credit 50,0000 1,000
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