Prescott Pharmaceuticals, a U.S.-based taxpayer, is a wholly owned subsidiary of an Austrian pharmaceutical company. Prescott pays royalties and interest expense to its Austrian parent.
Prescott Pharmaceuticals, a U.S.-based taxpayer, is a wholly owned subsidiary of an Austrian pharmaceutical company. Prescott pays royalties and interest expense to its Austrian parent. Prescotts U.S. taxable income for the current year appears below (amounts are in millions of U.S. dollars):
Revenues | $720 |
Cost of goods sold | 156 |
Research and development expense | 123 |
Salaries expense | 121 |
Other operating expense | 48 |
Royalties | 98 |
Interest expense | 54 |
Taxable income | $120 |
Prescott conducts its research and development activities in the U.S. and pays salaries to U.S. employees at five locations around the country. Prescott incurs other operating expenses within the U.S. Prescott has generated more than $500 million in revenues in each of its fifteen years of operation. The U.S. corporate tax rate is 21 percent.
Required:
Determine the amount of base erosion anti-abuse tax (BEAT), if any, that Prescott owes in the current year.
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