22. A controlled foreign corporation (CFC) realizes Subpart F income from:

a. Purchase of inventory from an unrelated U.S. person and sale outside the CFC country.

b. Purchase of inventory from a related U.S. person and sale outside the CFC country.

c. Services performed for the U.S. parent in a country in which the CFC was organized.

d. Services performed on behalf of an unrelated party in a country outside the country in which the CFC was organized.

23. Which of the following statements regarding the U.S. taxation of non-U.S. persons is true?

a. A non-U.S. persons effectively connected U.S. business income is taxed by the United States only if it is portfolio income.

b. A non-U.S. persons effectively connected U.S. business income is subject to U.S. income taxation.

c. A non-U.S. person may earn income from selling U.S. real property without incurring any U.S. income tax under any circumstances.

d. A non-U.S. person must spend at least 10 days in the United States before any effectively connected income is subject to U.S. taxation.

24. A Controlled Foreign Corporation is a subsidiary in which the U.S. shareholder owns more than

a. 10% of the voting power of the entity

b. 25% of the voting power of the entity

c. 50% of the voting power of the entity

d. 75% of the voting power of the entity

25. A U.S. Shareholder is a person who owns more than:

a. 10% of the of voting stock of the foreign corporation.

b. 20% of the of voting stock of the foreign corporation.

c. 30% of the of voting stock of the foreign corporation.

d. 40% of the of voting stock of the foreign corporation

26. All of the following statements are true about foreign tax credits except:

a. Foreign tax credit (FTC) provisions are designed to reduce the possibility of double taxation

b. Foreign Tax Credits can be claimed by U.S. citizens

c. Foreign Tax Credits can be claimed by foreign citizens

d. Creates a dollar for dollar reduction of U.S. income tax liability

27. How many years can you carry forward unused foreign tax credits?

a. 5

b. 10

c. 15

d. 20

28. How many days does a nonresident of a state have to be in residence for to meet the substantial presence test?

a. 100 days

b. 125 days

c. 183 days

d. 250 days

29. Non-US Corporations with a U.S. income tax liability files on which tax form?

a. Form 1120

b. Form 5471

c. Form 1120-F

d. Form 5881

30. U.S. Shareholders who own a portion of a Controlled Foreign Corporation file on which tax form?

a. Form 5471

b. Form 5881

c. Form 1120

d. Form 1040