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In 2021, Fendrich Inc. (a U.S. taxpayer) generated revenues of $600 million and incurred tax-deductible expenses of $500 million, resulting in U.S. taxable income of

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In 2021, Fendrich Inc. (a U.S. taxpayer) generated revenues of $600 million and incurred tax-deductible expenses of $500 million, resulting in U.S. taxable income of $100 million. Expenses include royalty payments and other base erosion payments, made to their offshore subsidiary FendBarb, amounting to $150 million. The Fendrich group as a whole averages more than $500 million revenue per year. In 2021, FendBarb (in Barbados) had QBAI of $100 million and recognized $230 million revenue with $125 million in operating expenses. FendBarb's average corporate income tax ratt, 2.5%. FendBarb was created as a wholly owned subsidiary in 2001 in Barbados. FendBarb has reported accumulated pre-tax earnings for the period 20012017 at $2,800 million. Accumulated pre-tax earnings allocated to the "held in cash" category is $2,000 million. None of the earnings generated by FendBarb have been repatriated back to Fendrich Inc. Although a portion of income generated by FendBarb is passive income, it has managed to avoid being treated as subpart F income. Any tax liability resulting from the DRAFE provision will be paid over the allowable 8-year period. Determine the amount of 2021 U.S. income tax liability for Fendrich U.S. regular income tax and the BEAT, DRAFE, and GILTI provisions of the 2017 TCJA. Be sure to provide supporting calculations and analysis. Record your answers below: Be sure to provide supporting calculations and analysis. Record your answers below: Supporting Calculations: In 2021, Fendrich Inc. (a U.S. taxpayer) generated revenues of $600 million and incurred tax-deductible expenses of $500 million, resulting in U.S. taxable income of $100 million. Expenses include royalty payments and other base erosion payments, made to their offshore subsidiary FendBarb, amounting to $150 million. The Fendrich group as a whole averages more than $500 million revenue per year. In 2021, FendBarb (in Barbados) had QBAI of $100 million and recognized $230 million revenue with $125 million in operating expenses. FendBarb's average corporate income tax ratt, 2.5%. FendBarb was created as a wholly owned subsidiary in 2001 in Barbados. FendBarb has reported accumulated pre-tax earnings for the period 20012017 at $2,800 million. Accumulated pre-tax earnings allocated to the "held in cash" category is $2,000 million. None of the earnings generated by FendBarb have been repatriated back to Fendrich Inc. Although a portion of income generated by FendBarb is passive income, it has managed to avoid being treated as subpart F income. Any tax liability resulting from the DRAFE provision will be paid over the allowable 8-year period. Determine the amount of 2021 U.S. income tax liability for Fendrich U.S. regular income tax and the BEAT, DRAFE, and GILTI provisions of the 2017 TCJA. Be sure to provide supporting calculations and analysis. Record your answers below: Be sure to provide supporting calculations and analysis. Record your answers below: Supporting Calculations

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