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Case 1 Case 2 a Foreign corporate income tax rate 28% 45% b U.S. corporate income tax rate 36% 36% c Foreign dividend withholding tax
Case 1 | Case 2 | |
a Foreign corporate income tax rate | 28% | 45% |
b U.S. corporate income tax rate | 36% | 36% |
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 | $3,500,000 | $3,500,000 |
2 Foreign corporate income tax | (980,000) | (1,575,000) |
3 Net income available for distribution | $2,520,000 | $1,925,000 |
4 Retained earnings | 0 | 0 |
5 Distributed earnings | 2520000 | 1925000 |
6 Distribution to U.S. parent company | 2520000 | 1925000 |
7 Withholding taxes on dividends | 378000 | 0 |
8 Net remittance to U.S. parent | $2,142,000 | $1,925,000 |
U.S. Corporate Tax Computation on Foreign Income | ||
9 Dividend received before withholding | $2,520,000 | $1,925,000 |
10 Add back foreign deem-paid tax | 980000 | 1575000 |
11 Grossed-up foreign dividend | $3,500,000 | $3,500,000 |
12 Tentative U.S. liability | 1260000 | 1260000 |
13 Less credit for foreign taxes | ||
a foreign income taxes paid | (980,000) | (1,575,000) |
b foreign withholding taxes paid | (378,000) | (0) |
c total | ($1,358,000) | ($1,575,000) |
14 Additional U.S. taxes due | $0 | $0 |
15 Excess foreign tax credits | 98000 | 315000 |
16 After-tax income from foreign subsidiary | $2,240,000 | $2,240,000 |
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