“Check-the-box” regulations can provide taxpayers with flexibility in choosing whether they wish to be taxed as a pass-through or corporate entity for U.S. tax purposes—depending on how the entity is organized under local law. Per se corporations can’t make an election to change their U.S. tax status. Please confirm if above statement is true or false: 

 

Group of answer choices

1. True

2. False

 

Confirm which of the following(s) are true

1. A territorial connection justifies the exercise of taxing jurisdiction because a taxpayer can be expected to share the costs of running in a country which makes possible the production of income, its maintenance and investment, and its use through consumption.

2. In the case of nationality, that connection is a legal one (e.g., citizenship or incorporation). In the case of territorial jurisdiction over a person, the connection is factual (e.g., whether that person is actually resident in a particular country).

3. In both cases it is the connection of the person to a country that justifies taxing jurisdiction.

Group of answer choices

a.  1, 2 and 3

b.  1 & 2

 

The source rules are important both to: (1) U.S. citizens, residents, and domestic corporations; and (2) nonresident alien individuals and foreign corporations. Which of the following are correct statements:

Group of answer choices

1. Interest is sourced by reference to the residence of the payor

2. A dividend paid by a domestic corporation is U.S. source income subject to the 30 percent tax under I.R.C. §§ 871(a) or 881.

3. Services performed in the United States is U.S. source income subject to a de minimis exception.

4. Rentals from the lease of tangible property are sourced where the property is located.

5. all of above

6. 1, 2 & 4

 

Gain from the sale of any patent, copyright, secret process or formula, goodwill, trademark, trade brand, or similar intangible is sourced in one of two ways depending on the nature of the sale. Which of the following are correct:

Group of answer choices

1. If the sales proceeds are contingent on the productivity, use, or disposition of the intangible, any gain is sourced as if the payments received were royalties.

2. If the sales proceeds are not contingent on the use of the intangible, any gain is sourced by reference to the residence of the seller.

3. If the sales contract has both a non-contingent and contingent aspect, the amounts are sourced to the residence of seller.

4. all of above

5. 1 &2