Question
US Corp owns 100% for For Corp, a foreign corporation. For Corp's net income is 17.6 million (taxed at 12%), of which 5 million is
US Corp owns 100% for For Corp, a foreign corporation. For Corp's net income is 17.6 million (taxed at 12%), of which 5 million is Subpart F income (taxed at 12%). If For Corp has depreciable tangible assets with an average quarterly adjusted basis of 15 million, and net specified interest expense of .5 million not included in tested income, what is US Corp's GILTI amount?
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Lease Audits The Essential Guide
Authors: Theodore H Hellmuth
1st Edition
0934055041, 978-0934055048
