Question
FOR QUESTIONS 6 AND 7: ForCo, a corporation that is incorporated in a foreign country and does not have a treaty with the U.S., plans
FOR QUESTIONS 6 AND 7: ForCo, a corporation that is incorporated in a foreign country and does not have a treaty with the U.S., plans to conduct manufacturing, marketing, and sales operations in the U.S. These U.S. operations produce $5 million of earnings and profits in Year 1. Further assume that the U.S. operations will have a net worth of $20 million at the beginning of Year 1 and $20 million at the end of Year 1. During Year 2, the U.S. branch does not produce any earnings and profits and its net worth is $20 million at the beginning of the year and $10 million at the end of the year.
6) For branch profits tax purposes in Year 1, the dividend equivalent amount for the U.S. branch is as follows:
| a. | $5 million |
| b. | $10 million |
| c. | $20 million |
| d. | $25 million |
| e. | $1.5 million |
7) For branch profits tax purposes in Year 2, the dividend equivalent amount for the U.S. branch is as follows:
| a. | $5 million |
| b. | $10 million |
| c. | $20 million |
| d. | $25 million |
| e. | $3 million |
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