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Entities C, F, and G manufacture products that are sold in their home countries as well as to sister entities within the WUC group. Entity

  1. Entities C, F, and G manufacture products that are sold in their home countries as well as to sister entities within the WUC group.
  2. Entity A purchases finished products from Entity F and then sells them throughout the Middle East. Only 5 percent of A's income is generated from sales to customers in Bahrain; 95 percent of A's income is from sales to foreign customers.
  3. Entity B purchases finished products from Entity G and sells them throughout North and South America. Only 1 percent of B's income is from sales to customers in Bermuda; 99 percent of B's income is from sales to foreign customers.
  4. Entity D purchases finished products from Entity C and then sells them throughout Europe. Only 40 percent of D's income is generated from sales to customers in Hungary; 60 percent of D's income is from sales to foreign customers.
  5. Entity E makes passive investments in stocks and bonds in European financial markets. All of E's income is derived from dividends and interest.
  6. Entity H provides accounting and other management services to WUC's other foreign operations. All of H's income is derived from providing services to sister companies within the WUC group.

  1. Determine the amount of U.S. taxable income for each entity (A, B, C, D, E, F, G, and H).

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Dividend Net Dividend Legal Income Income Withholding Received by Entity Country Form Activity before Tax Tax Rate Tax Rate Parent IOTMOODE Bahrain Branch Sales $ 1,000,000 0% 0% $1,000,000 Bermuda Corporation Sales 8,000,000 O 8,000,000 Hong Kong Corporation Manufacturing 10,000,000 16.5 8,350,000 Hungary Corporation Sales 10,000,000 9 9,100,000 Ireland Corporation Investment 2,000,000 12.5 1,750,000 Malaysia Branch Manufacturing 10,000,000 24 7,600,000 Mexico Corporation Manufacturing 5,000,000 30 3,3250,000 Switzerland Corporation Service 500,000 17 269,750

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