CASE NINE

U.S. International Corporation, textbook page 584. Use the following table instead of the one given in the book.

Entity Country Percent Activity Income Income Dividend Net amount

Owned before tax tax rate withholding received by

$millions tax rate parent $mil.

USIC US ----- Manufacturing $10 35% ---- ----

A Argentina 100% Manufacturing 1 35% 0% $0.2

B Brazil 100% Manufacturing 2 34% 0% $2.5*

C Canada 100% Manufacturing 3 33% 5% $1.0

D Hong Kong 100% Investment 2 16.5% 0% $1.5

E Liechtenstein 100% Distribution 3 10% 4% $0.0

F Japan 51% Manufacturing 2 40% 5% $0.5

G New Zealand 60% Banking 4 30% 15% $1.0

*Some dividends were paid out of beginning-of-year retained earnings.

1. USICs $10 million income before tax is derived from the production and sale of products in the United States. 2. Each entity is legally incorporated in its host country other than Entity A, which is registered with the Argentinian government as a branch. 3. Entities A, B, C, and F produce and market products in their home countries. 4. Entity D makes passive investments in stocks and bonds in the Hong Kong fnancial markets. Income is derived solely from dividends and interest. 5. Entity E markets goods purchased from (manufactured by) USIC. Of Es sales, 95 percent are made in Austria, Germany, and Switzerland, and 5 percent are

made in Liechtenstein. 6. Entity G operates in the fnancial services industry in New Zealand. Required Determine the following: a. The amount of U.S. taxable income for each Entity AG. b. The foreign tax credit allowed in the United States, first by basket and then in total. c. The net U.S. tax liability. d. Any excess foreign tax credits (identify by basket)