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In 2022, Copco Inc. (a U.S. taxpayer) generated revenues of $600 million and incurred tax-deductible expenses of $480 million, resulting in U.S. taxable income of

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In 2022, Copco Inc. (a U.S. taxpayer) generated revenues of $600 million and incurred tax-deductible expenses of $480 million, resulting in U.S. taxable income of $120 million. Expenses include royalties and other base erosion payments, made to their offshore subsidiary CopcoBer, amounting to $200 million. The Copco group averages more than $500 million in revenue per year. In 2022, CopcoBer (in Bermuda) had QBAI of $50 million and recognized $200 million revenue with $35 million in operating expenses. CopcoBer's average corporate income tax rate is 5.0%. CopcoBer was created as a wholly owned subsidiary in 2001 in Bermuda. CopcoBer has reported accumulated pre-tax earnings for the period 2001-2017 at $2,300 million. Accumulated pre-tax earnings allocated to the "held in cash" category is $1,800 million. $300 million of the earnings generated by CopcoBer have been previously repatriated back to Copco Inc. Income generated by CopcoBer does not meet the criteria for subpart F income. Any tax liability resulting from the DRAFE provision will be paid over the allowable 8-year period. Determine the amount of 2022 U.S. income tax liability for Copco Inc. That consists of regular income tax plus additional tax due in 2022 resulting from the BEAT, DRAFE, and GILTI provis. is of the 2017 TCIA. Be sure to provide supporting calculations and analysis. Record your answers below: Determine the amount of 2022 U.S. income tax liability for Copco Inc. That consists of regular income tax plus additional tax due in 2022 resulting from the BEAT, DRAFE, and GILTI provisions of the 2017 TCJA. Be sure to provide supporting calculations and analysis. Record your answers below: Supporting Calculations

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