Question
Hi, I don't understand how to calculate this answer. I understand FTC and excess FTC but I am not sure how to proceed in this
Hi, I don't understand how to calculate this answer. I understand FTC and excess FTC but I am not sure how to proceed in this scenario. Can you help me walk through the problem?
D, a domestic corporation, has a branch office located within country X. D's management projects that in the next taxable year, D will have a pre-tax profit of $1,000, $800 from U.S. operations and $200 from the branch in X. Assume X taxes corporate income at a rate of 31%, and the United States taxes corporate income at a rate of 21% Now assume that the rules X uses to source income differ from those used by the United States. For example, X may use an activity-based sourcing rule for income from inventory sales whereas the United States uses a title passage rule. Therefore, D may be able to restructure its operations such that a portion of the $800 profit currently classified as U.S. source income is recharacterized as foreign source income, but only for U.S. tax purposes. How much of the $800 profit would have to be recharacterized as foreign source income in order to eliminate the excess credit generated by the country X branch? Each dollar of resourced income will: - increase D's FTC limitation by ______ and - has no effect on foreign tax paid to country X. To completely eliminate the excess FTC in part 1, D needs to resource income of __________
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