Question
Euro Corporation, a U.S. corporation, operates through a branch in Germany. During 2021, the branch reported taxable income of $1,005,000 and paid German income taxes
Euro Corporation, a U.S. corporation, operates through a branch in Germany. During 2021, the branch reported taxable income of $1,005,000 and paid German income taxes of $301,500. In addition, Euro received $50,200 of dividends from its 5 percent investment in the stock of Maple Leaf Company, a Canadian corporation. The dividend was subject to a withholding tax of $5,020. Euro reported U.S. taxable income from its manufacturing operations of $954,800. Total taxable income was $2,010,000. Pre-credit U.S. taxes on the taxable income were $422,100. Included in the computation of Euros taxable income were definitely allocable expenses of $502,500, 50 percent of which were related to the German branch taxable income. Complete pages 1 and 2 of Form 1118 for just the foreign branch income reported by Euro. (Use 2021 tax rules regardless of year on tax form.)
Form 1118 (Rev. 12-2020)Page 2Schedule BForeign Tax Credit (Report all foreign tax amounts in U.S. dollars.)Part IForeign Taxes Paid, Accrued, and Deemed Paid (see instructions)1. Credit Is Claimed for Taxes (check one):2. Foreign Taxes Paid or Accrued (attach schedule showing amounts in foreign currency and conversion rate(s) used)Paidcheckbox unchecked1 of 2Accruedcheckbox unchecked2 of 2Tax Withheld at Source on:Date PaidDate Accrued(a) Dividends(b) Distributions of Previously Taxed Income(c) Branch Remittances(d) Interest(e) Rents, Royalties, and License Fees(f) OtherABCTotals (add lines A through C)2. Foreign Taxes Paid or Accrued (attach schedule showing amounts in foreign currency and conversion rate(s) used)3. Tax Deemed Paid (see instructions)Other Foreign Taxes Paid or Accrued on:(j) Total Foreign Taxes Paid or Accrued (add columns 2(a) through 2(i))(g) Sales(h) Services Income(i) OtherABCTotalsPart IISeparate Foreign Tax Credit (Complete a separate Part II for each applicable category of income.)1aTotal foreign taxes paid or accrued (total from Part I, column 2(j))bForeign taxes paid or accrued by the corporation during prior tax years that were suspended due to the rules of section 909 and forwhich the related income is taken into account by the corporation during the current tax year (see instructions)2Total taxes deemed paid (total from Part I, column 3)3Reductions of taxes paid, accrued, or deemed paid (enter total from Schedule G)4Taxes reclassified under high-tax kickout5Enter the sum of any carryover of foreign taxes (from Schedule K, line 3, column (xiv), and from Schedule I, Part III, line 3)carrybacks to the current tax year6Total foreign taxes (combine lines 1a through 5)7Enter the amount from the applicable column of Schedule J, Part I, line 11 (see instructions). If Schedule J is not required to be completed,enter the result from the Totals line of column 18 of the applicable Schedule A8aTotal taxable income from all sources (enter taxable income from the corporations tax return)bAdjustments to line 8a (see instructions)cSubtract line 8b from line 8a9Divide line 7 by line 8c. Enter the resulting fraction as a decimal (see instructions). If line 7 is greater than line 8c, enter 110Total U.S. income tax against which credit is allowed (regular tax liability (see section 26(b)) minus any American Samoa economic development credit)11Multiply line 9 by line 1012Increase in limitation (section 960(c)) .Form 1118 (Rev. 12-2020)THIS FORM IS A SIMULATION OF AN OFFICIAL U.S. TAX FORM. IT IS NOT THE OFFICIAL FORM ITSELF. DO NOT USE THIS FORM FOR TAX FILINGS OR FOR ANY PURPOSE OTHER THAN EDUCATIONAL. 2021 McGraw-Hill Education.
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