Question
Sombrero Corporation, a U.S. corporation, operates through a branch in Espania. Management projects that the companys pretax income in the next taxable year will be
Sombrero Corporation, a U.S. corporation, operates through a branch in Espania. Management projects that the companys pretax income in the next taxable year will be $122,200: $99,200 from U.S. operations and $23,000 from the Espania branch. Espania taxes corporate income at a rate of 30 percent.
a. If management's projections are accurate, what will be Sombrero's excess foreign tax credit in the next taxable year? Assume all of the income is foreign branch income.
b. Management plans to establish a second branch in Italia. Italia taxes corporate income at a rate of 10 percent. What amount of income will the branch in Italia have to generate to eliminate the excess credit generated by the branch in Espania?
Excess foreign tax credit Income
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