Please help me with the problem sets in the attached file. elaborate in details if you could, thanks

Problem 1 (9 points) US Golf (\"USG\"), a US corporation, manufactures red golf balls and blue golf balls in the US and sells them to EuroCo, a Netherlands corporation which is 100% owned by USG. EuroCo packages the red balls and sells them to independent distributors outside of the Netherlands for a gain of $100. EuroCo packages the blue balls and sells them to independent distributors in the Netherlands for a gain of $200. EuroCo buys white golf balls from an unrelated Japanese manufacturer and sells them to an independent distributor outside of the Netherlands for a gain of $300. How much, if any, of this income is Subpart F income? Please explain why it is, or is not, Subpart F income? EuroCo enters into a contract manufacturing agreement with Callahan, an Irish golf club manufacturer. Under the agreement, Callahan agrees to manufacture golf clubs for EuroCo. EuroCo pays for Callahan's expenses and is responsible for all risk of loss. EuroCo then sells the golf clubs to unrelated buyers throughout Europe. Is the income from the sale of golf clubs Subpart F income? Please explain why it is, or is not, Subpart F income and what body of law you are relying upon to reach your conclusion? Problem 2 (9 points) In 2012, USCo, a US corporation, earned $1000 of US source income and $1000 of foreign source income. USCo paid $200 of foreign tax on the foreign source income. In 2013, USCo earned $1000 of US source income and $3000 of foreign source income. USCo paid $1500 of foreign tax on the foreign source income. In 2014,USCo earned $2000 of US source income and $2000 of foreign source income. USCo paid $400 of foreign tax on the foreign source income. Assume the US tax rate is 35%. How much foreign tax credit will USCo be able to take in 2012, 2013 and 2014? What is USCo's post-credit US tax liability in 2012, 2013 and 2014? Problem 3 (8 points) NetCo, a US corporation, is planning to start operating in Argentina. NetCo has formed a 100% owned subsidiary in Argentina, ArgCo. NetCo contributes a number of assets to ArgCo in exchange for all of ArgCo's stock. ArgCo will use the assets in an active trade/business. The assets contributed include the following: - Accounts receivable with a basis of $20,000 and a fair market value of $65,000, Equipment that was purchased for $250,000 and depreciated over the years such that the current adjusted basis is $190,000. The fair market value of the equipment is $260,000, - Inventory that cost $50,000 has a value of $80,000, and - Non-depreciable equipment that was purchased for $110,000 and has a fair market value of $165,000. What are the tax consequences for NetCo when it contributes these assets to ArgCo in exchange for ArgCo stock? Problem 4 (10 points) InterCorp, an Industrian corporation, has 100 shares of one class of stock outstanding which is owned by the following shareholders: 40 shares by USCo Inc., a publicly held US corporation, 20 shares by Sam, a US citizen who resides in Venezuela, 15 shares by Angelina, a citizen and resident of Industria, 4 shares by Fred, a US citizen residing in the US, 6 shares by Alex, Fred's brother who is also a US citizen residing in the US, 14 shares by Michael, a Spanish citizen who has a US green card, and 1 share by James, a Jamaican citizen who spends 200 days a year in the US. During 2014, InterCorp has $10 million of income having the following character: $4 million in foreign source dividends and interest from unrelated person, $1 million in income from an active foreign business which constitutes foreign base company sales income, and $5 million in income from an active foreign business which does not constitute foreign base company sales income. InterCorp has no deductions in 2003. During 2014, Inter Corp's assets consist of the following: Assets that are used to conduct its trade or business activities which have an average value of $50 million and average adjusted bases of $25 million, and Assets producing passive income or held for the production of passive income which have an average value of $60 million and average adjusted bases of $35 million. Is InterCorp a CFC in 2014? Why or why not? Is InterCorp a PFIC in 2014? Why or why not? Do any of InterCorp's shareholders receive deemed dividends from InterCorp? If so, which shareholders and how much does each receive? Would you advise any of the shareholders to make a QEF election? If so which ones? What would be the effect of a QEF election? Problem 5 (7 points) DC, a U.S. corporation, operated a branch in Islandia for three years with the following results: Year Branch Net Income (Loss) 2010 ($1,000) 2011 ($2000) 2012 $ 500 DC also earned $5,000 from its U.S. business activities in each of these three years. On January 1, 2013, DC formed FC, an Islandian corporation, and transferred the branch's assets to FC. At the time of the transfer, DC's basis in the branch's assets was $1,000 and the fair market value of the branch's assets was $5,000. The assets only consisted of equipment which was not subject to depreciation. What amount, if any, must DC include in its gross income in 2013? What is FC's basis in the branch's assets after the transfer? Assume that DC forms FC on January 1, 2014 instead of 2013. Also assume that in 2013 DC's Islandian branch had Net Income of $3000. How would your answer change? Problem 6 (10 points) BlueCo is a US corporation with multiple business activities. On January 1, 2014, BlueCo granted a non-exclusive license of foreign patents to Rosso Ltd., an unrelated foreign corporation. On January 1, 2014, BlueCo also acquired a 5-percent interest in BianCo, a manufacturing corporation organized under the laws of Switzerland. The remaining 95% of the stock of BianCo is owned by an unrelated Swiss corporation. In addition, on January 1, 2014, BlueCo established a sales branch in Germany to handle foreign sales of the products BlueCo manufactures in the United States. All income (or loss) of the branch is sourced in Germany. BlueCo's income in 2014 was composed of the following items: -BlueCo received royalties from the license to Rosso of $100,000, which were subject to an Industrian withholding tax of forty percent. -BlueCo's German sales branch received $100,000 of sales income, on which it paid German corporate income tax of $45,000. -BlueCo received interest income from BianCo of $150,000 which was subject to a Swiss withholding tax of 10%. -BlueCo had $700,000 of taxable income from its US operations all sourced in the United States. Assume that the U.S. tax rate is 35%. How much foreign tax will BlueCo be allowed to credit for 2014? How much tax would be due in the U.S.? Problem 7 (9 points) HealthWest, a US Corporation owns 100% of EuroHealth, a Luxembourg holding corporation. EuroHealth is a holding company and does not conduct any business activities. EuroHealth owns 100% of two subsidiaries: BelHealth, a Belgian corporation, and LuxHealth, a Luxembourg corporation. EuroHealth's only assets are shares of its two subsidiaries. EuroHealth's only income is dividend payments from its subsidiaries of $120 each. LuxHealth buys exercise equipment manufactured by HealthWest and sells it in France and the Netherlands and realizes a gain of $500 on the sale of the equipment. BelHealth purchases exercise equipment from HealthWest and sells it in Belgium and realizes a gain of $400 on the sale of the equipment. How much of EuroHealth's income is Subpart F income? How much of BelHealth's income is Subpart F income? How much of LuxHealth's income is Subpart F income? What is the total amount of Subpart F income that HealthWest must include as income in the current year? Problem 8 (8 points) DP, a U.S. corporation, has two wholly owned subsidiaries, DS, a U.S. corporation, and FS, a foreign subsidiary incorporated in country X. DS manufactures hammers at a cost of $10 per unit and sells them to FS for $12 per unit. FS sells them to unrelated retailers in country X for $25 per unit. DS also sells the same hammers to Indy, an unrelated tool distributor in the country X, for $16 per unit. DP sells screwdrivers to Indy for $12 per unit and Indy resells the screwdrivers to retailers for $15 per unit in country X. DP also manufactures wrenches for a cost of $5 per unit and sells them to Indy for $7.50 per unit. What is the appropriate transfer price for the hammers sold by DS to FS using the Comparable Uncontrolled Price Method? What is the appropriate transfer price for the hammers sold by DS to FS using the Resale Price Method? What is the appropriate transfer price for the hammers sold by DS to FS using the Cost Plus Method