1.FORCo, a subsidiary of a U.S. corporation, is incorporated in Brazil. FORCo manufactures widgets in Brazil and sells them to its 100% owned subsidiary in Hungary. FORCo's incomefrom the sale of its widgets is not Subpart F foreign base company sales income.

(a) True

(b) False

2. For U.S. residents to obtain treaty-reduced rates, many U.S. treaty partners require the IRS to certify that the person claiming treaty benefits is a resident of the United States for federal tax purposes. A U.S. resident will be required to furnish a:

(a) Form6166

(b) FormW-8BEN

(c) FormW-8BEN-E

(d) Form5471

3.USCo, a U.S. corporation, decides to expand its sales in Italy by hiring a

salesperson there. Neither USCo nor the salesperson lease commercial office space

in Italy. The salesperson makes sales calls while performing the necessary administrative paperwork in his office at his home in Italy. The salesperson does not have the authority toconclude sales contracts in USCo's name.Under the Model Treaty:

(a) USCo is subject to tax in Italybecause the salesperson's office constitutes

a permanent establishment.

(b) USCo is not subject to tax in Italybecause the salesperson's office does

not constitute a permanent establishment.

(c) USCo is not subject to tax in Italy because USCo is not engaged in a

trade or business.

(d) None of the above.