Answered step by step
Verified Expert Solution
Question
1 Approved Answer
Entity Country Percent Owned Activity Income before Tax ($ millions) Income Tax Rate Dividend Withholding Tax Rate Net Amount Received by Parent ($ millions) USIC
Entity | Country | Percent Owned | Activity | Income before Tax ($ millions) | Income Tax Rate | Dividend Withholding Tax Rate | Net Amount Received by Parent ($ millions) | |
USIC | USA | - | Manufacturing | $10.00 | 35% | - | - | |
A | Argentina | 100% | Manufacturing | $1.00 | 35% | 0% | $0.20 | |
B | Brazil | 100% | Manufacturing | $2.00 | 34% | 0% | $2.50 | |
C | Canada | 100% | Manufacturing | $3.00 | 26% | 5% | $1.00 | |
D | Hong Kong | 100% | Investment | $2.00 | 16.50% | 0% | $1.50 | |
E | Liechtenstein | 100% | Distribution | $3.00 | 10% | 4% | $ - | |
F | Japan | 51% | Manufacturing | $2.00 | 38% | 5% | $0.50 | |
G | New Zealand | 60% | Banking | $4.00 | 28% | 5% | $1.00 | |
Additional Information | ||||||||
1 | USIC has $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 financial markets Income is derived solely from dividends and interest | |||||||
5 | Entity E markets good purchased from (manufactured by) USIC Of Es sales, made in Liechtenstein | |||||||
6 | Entity G operates in the chemical industry in New Zealand | |||||||
Required: | ||||||||
Determine the following: | ||||||||
a | The amount of U.S. taxable income for each Entity A-G | |||||||
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) | |||||||
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started