Question
2021 Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50 percent owned
2021
Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50 percent owned joint venture, CanCo. CanCo is treated as a corporation for U.S. and Canadian tax purposes. An unrelated Canadian investor owns the remaining 50 percent. Windmill conducts its operations in Ireland through a wholly owned subsidiary, IrishCo. IrishCo is a controlled foreign corporation for U.S. tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid entity, KiwiCo. KiwiCo is treated as a branch for U.S. tax purposes and a corporation for Australian tax purposes. Windmill also owns a 5 percent interest in a Dutch corporation, TulipCo. During 2020, Windmill reported the following foreign source income from its international operations and investments.
CanCo | IrishCo | KiwiCo | TulipCo | |||||
Dividend income | ||||||||
Amount | $ | 64,200 | $ | 72,800 | $ | 32,800 | ||
Withholding tax | 3,210 | 3,640 | 4,920 | |||||
Interest income | ||||||||
Amount | $ | 46,000 | ||||||
Withholding tax | 0 | 0 | ||||||
Branch income | ||||||||
Taxable income | $ | 117,000 | ||||||
AUS income taxes | $ | 39,000 | ||||||
Note: CanCo and KiwiCo derive all of their earnings from active business operations.
Requirement:
- Classify the income received by Windmill into the appropriate FTC baskets.
- Windmill has $1,282,000 of U.S. source gross income. Windmill also incurred SG&A of $332,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCos gross income is $307,200. Compute the FTC limitation for each basket of foreign source income.
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