Question 32 of 44 2 Points To transition to the "semir-territorial tax system, which allows for tax-free repatriations of distributed future foreign profits, a one- time repatriation tax is imposed on U.S. taxpayers' previously deferred offshore earnings. For corporate 10% U.S. shareholders, this one-time deemed repatriation tax is imposed at a: A. 15.5% rate on earnings held in cash and an 8% rate on earnings held otherwise. B.21% rate on earnings held in cash and an 10.5% rate on earnings held otherwise. C.8% rate on earnings held in cash and an 15.5% rate on earnings held otherwise. D. 10.5% rate on earnings held in cash and an 21% rate on earnings held otherwise. Reset Selection Question 33 of 44 2 Points USACO, a domestic corporation, is in the 21% income tax bracket. USAco earns $100,000 of U.S.-source income and $100,000 of (general basket) foreign-source income. USAco's foreign tax credit limitation is: A. $0. B. $21,000. C. $42,000. D. $100,000. Reset Selection Question 34 of 44 2 Points Which of the following is not a category of Foreign Base Company Income? A. Foreign personal holding company income B. Foreign base company sales income C. Foreign base company manufacturing income D. Foreign base company services income Reset Selection Question 35 of 44 2 Points USAco, a domestic corporation, sells widgets throughout Europe. USAco forms CAYCO, a Cayman Islands corporation. The Cayman Islands does not have a corporate income tax. CAYco engages independent contractors to provide repair services to USAco's European customers. USAco pays CAYco for these services. The income of CAYco is: A. foreign base company sales income. B. foreign personal holding company income. C. foreign base company services income. D. regular deferred foreign income. Reset Selection Question 36 of 44 2 Points USACO, a domestic corporation, owns 100% of FORco, a country F corporation. 60% of FORco's gross income for the taxable year is passive income and the average market value of FORco's passive assets during the taxable year is 60% of the corporation's total assets. FORco is a Passive Foreign Investment Company ("PFIC") because it meets which test(s)? A. The income test B. The asset test C. Both the income and asset test D. Neither, it's not a PFIC Reset Selection