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Bryson Inc is a U . S . resident taxpayer who conducts its foreign operations through Banks, Ltd located in Germany. Bryson owns 1 0
Bryson Inc is a US resident taxpayer who conducts its foreign operations through Banks, Ltd located in Germany. Bryson owns of Banks. During the current year Bryson sells products to Banks for $ that cost Bryson $ to produce. Banks then sells those products directly to customers for $ In addition, Bryson makes sales in the US of $ for products that cost $ to produce. At the end of the year Banks then sends $ to Bryson. Assume Banks pays NonUS taxes of $
A What is Bryson's US taxable income from the above transactions if Banks is treated as a branch?
B What is Bryson's US taxable income if Banks is a set up as a foreign subsidiary and all of its sales are to customers in Germany?
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