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Dollin Inc. is incorporated under Virginia law and has its corporate headquarters in Richmond. Dollin is a distributor; it purchases tangible goods from manufacturers and
Dollin Inc. is incorporated under Virginia law and has its corporate headquarters in Richmond. Dollin is a distributor; it purchases tangible goods from manufacturers and sells the goods to retailers. It has a branch office through which it sells goods in the United Kingdom and owns 100 percent of a French corporation (French Dollin) through which it sells goods in France. Dollins financial records provide the following information for the year:
Before-tax net income from sales: | |||
Domestic sales | $ | 967,900 | |
UK sales (foreign source income) | 415,000 | ||
$ | 1,382,900 | ||
Dividend income: | |||
Brio Inc. | $ | 8,400 | |
French Dollin (foreign source income) | 33,800 | ||
- Dollin pays state income tax in Virginia, North Carolina, and South Carolina. All three states tax their apportioned share of Dollins net income from worldwide sales. Because Virginia is Dollins commercial domicile, it also taxes Dollins U.S. source (but not foreign source) dividend income net of any federal dividends-received deduction. The states have the following apportionment factors and tax rates:
Apportionment Factor Tax Rate Virginia 43.19 % 6.00 % North Carolina 11.02 % 7.75 % South Carolina 39.52 % 5.00 % - Dollin paid $149,200 income tax to the United Kingdom.
- Dollin elects to claim the foreign tax credit rather than to deduct foreign income taxes. Brio Inc. is a taxable U.S. corporation. Dollin owns 2.8 percent of Brios stock.
- Dollin has owned 100 percent of the stock of French Dollin for 10 years. None of French Dollin's earnings are considered GILTI or subpart F income.
- Earnings of the UK branch are not considered FDII.
- Compute Dollins state income tax for Virginia, North Carolina, and South Carolina.
- Compute Dollins federal income tax. Assume that Dollin paid the state taxes during the year, and no state income tax is allocable to foreign source income.
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