Question
Beatco, an accrual basis domestic corporation, manufactures musical instruments for sale both in the United States and abroad. Beatcos functional currency is the U.S. dollar.
Beatco, an accrual basis domestic corporation, manufactures musical instruments for sale both in the United States and abroad. Beatcos functional currency is the U.S. dollar. Two years ago, Beatco established a branch sales office in Switzerland. The sales office is a qualified business unit with the Swiss franc (CHF) as its functional currency. In Year 1, the branch had CHF80 million of taxable income, and paid CHF30 million of Swiss income taxes. The Swiss franc had an average exchange rate in Year 1 of CHF1 equals $1.10.
What are the U.S. tax consequences of the branchs activities in Year 1?
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