Question
1.Assume a US taxpayer develops computer software in the US and then sells the rights to the software to a French corporation, which will use
1.Assume a US taxpayer develops computer software in the US and then sells the rights to the software to a French corporation, which will use the software in France. As payment for the sale, the French corporation pays the US corporation $1 million, which is not contingent on use of or any revenue generated by the copyright. The revenue/gain from the sale is
a.US source income
b.French source income
c.50% US source income and 50% French source income
d.Neither US source income nor French source income
2.Assume a French corporation sells a patent to another French corporation for $10 million. The patent will be used in France. The seller has a basis in the patent of $4 million. The patent had previously been used by the seller in the US and a total of $1 million of amortization had been deducted by the seller on its US tax returns. How much, if any, of the gain is US source income?
a.0
b.$6 million
c.$1 million
d.$2 million
3.Assume a US taxpayer develops computer software in the US and then sells the rights to the software to a French corporation, which will use the software in France. As payment for the sale, the French corporation will pay the US corporation 10% of the revenue that is generated from the sue of the copyright for a 10 year period. $ The revenue/gain from the sale is:
a.US source income
b.French source income
c.50% US source income and 50% French source income
d.Neither US source income nor French source income
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