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?Avon's Foreign-Source Income. Avon is a? U.S.-based direct seller of a wide array of products. Avon markets leading? beauty, fashion, and home products in more

?Avon's Foreign-Source Income. Avon is a? U.S.-based direct seller of a wide array of products. Avon markets leading? beauty, fashion, and home products in more than 100 countries. As part of the training in its corporate treasury? offices, it has its interns build a spreadsheet analysis of the following hypothetical subsidiary? earnings/distribution analysis. Use the tax analysis presented in the table below for your basic? structure.

a. What is the total tax? payment, foreign and domestic? combined, for this? income?

b. What is the effective tax rate paid on this income by the? U.S.-based parent? company?

c. What would be the total tax payment and effective tax rate if the foreign corporate tax rate was 45% and there were no withholding taxes on? dividends?

d. What would be the total tax payment and effective tax rate if the income was earned by a branch of the U.S.? corporation?

Case 1 Case 2
a Foreign corporate income tax rate 28% 45%
b U.S. corporate income tax rate 35% 35%
c Foreign dividend withholding tax rate 15% 0%
d U.S. ownership in foreign firm 100% 100%
e Dividend payout rate of foreign firm 100% 100%
Foreign Subsidiary Tax Computation
1 Taxable income of foreign subsidiary $3,400,000 $3,400,000
2 Foreign corporate income tax (952,000) (1,530,000)
3 Net income available for distribution $2,448,000 $1,870,000
4 Retained earnings 0 0
5 Distributed earnings 2448000 1870000
6 Distribution to U.S. parent company 2448000 1870000
7 Withholding taxes on dividends 367200 0
8 Net remittance to U.S. parent $2,080,800 $1,870,000
U.S. Corporate Tax Computation on Foreign Income
9 Dividend received before withholding $2,448,000 $1,870,000
10 Add back foreign deem-paid tax 952000 1530000
11 Grossed-up foreign dividend $3,400,000 $3,400,000
12 Tentative U.S. liability 1190000 1190000
13 Less credit for foreign taxes
a foreign income taxes paid (952,000) (1,530,000)
b foreign withholding taxes paid (367,200) (0)
c total ($1,319,200) ($1,530,000)
14 Additional U.S. taxes due $0 $0
15 Excess foreign tax credits 129200 340000
16 After-tax income from foreign subsidiary $2,210,000

$2,210,000

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