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ELM Company has a 21 percent U.S. tax rate plans to expand its business into Country X. It could open a branch office, or it
ELM Company has a 21 percent U.S. tax rate plans to expand its business into Country X. It could open a branch office, or it could create a foreign subsidiary in Country X. The branch office would generate $5,000,000 income in year O. The foreign subsidiary would incur incremental legal costs and, as a result, would generate only $4,750,000 income in year 0. This income would be taxed at Country X's 15 percent corporate rate. Any repatriation of the subsidiary's earnings would qualify for the 100 percent dividends-received deduction. (None of the subsidiary's earnings would be considered GILTI or subpart F income) Requirements: Determine the following for ELM Company's foreign earnings: If the company opens a branch office (1) Country X's tax on foreign earnings from branch office: (2) After-tax foreign source income from branch office: If the company creates a foreign subsidiary (3) Country X's tax on foreign earnings from subsidiary: (4) After-tax foreign source income from subsidiary
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