Question
Linetti Corp is a U.S. resident corporation. They operate their Non-U.S. operations through a wholly owned subsidiary located in the Netherlands Dwight, Inc. Dwight also
Linetti Corp is a U.S. resident corporation. They operate their Non-U.S. operations through a wholly owned subsidiary located in the Netherlands Dwight, Inc. Dwight also owns the patent which underlies the production process Linetti uses to make their products.
During the year Linetti reports the following activity
U.S. Sales | $ 1,200,000 |
Non-U.S. sales | 500,000 |
License Fee Paid to Dwight for Use of Patent to produce products for U.S. Sales | (100,000) |
Foreign taxes | (30,000) |
| |
COGS |
|
On U.S. Sales | (700,000) |
On Non-U.S. Sales | (150,000) |
On Products Sold to Dwight | (50,000) |
Total COGS | (900,000) |
And Dwight reports the following additional information:
Purchase of raw materials from Linetti | (250,000) |
Additional COGS to transform raw materials to finished products | (50,000) |
Sales to Non-U.S. customers outside of the Netherlands | 500,000 |
Assume that the Netherlands has a corporate tax rate of 0%. Also, Linettis annual gross receipts over the prior three tax years are $2,000,000.
Required: What is Linettis net tax due to the U.S. as a result of the above transactions?
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