INTRODUCTION Case 8-1 Worldwide United Corporation Worldwide United Corporation (WUC), a U.S. taxpayer, manufactures and sells products through a network of foreign branches and wholly-owned foreign subsidiaries. Relevant information for these entities for the current fiscal year appears in the following table: ABCDEFGI Entity Country Bahrain Legal Form Branch Activity Sales Income before Tax Income Dividend Withholding Net Dividend Tax Rate Tax Rate Received by Parent $1,000,000 0% 0% $1,000,000 Bermuda Corporation Sales 8,000,000 0 0 8,000,000 Hong Kong Corporation Manufacturing 10,000,000 16.5 0 8,350,000 Hungary: Corporation Sales 10,000,000 9 0 9,100,000 Ireland Corporation Investment 2,000,000 12.5 0 1,750,000 Malaysia Branch Manufacturing 10,000,000 Mexico Corporation Manufacturing 5,000,000 H Switzerland Corporation Service 500,000 2875 24 0 7,600,000 30 5 3,3250,000 17 35 269,750