Question
U.S. individual owns ForCO, a domestic C corporation that owns a CFC. The CFC owns $10 million of tangible property, earns $2 million of tested
U.S. individual owns ForCO, a domestic C corporation that owns a CFC. The CFC owns $10 million of tangible property, earns $2 million of tested income, and pays $200,000 of foreign income taxes.
a. How much, if any, is ForCO GILTI?
b. How much is ForCO U.S. income tax?
c. Assume the U.S. Individual owns the CFC directly, do your answers to a & b above change? Explain.
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South Western Federal Taxation 2017 Corporations, Partnerships, Estates And Trusts
Authors: William H. Hoffman, William A. Raabe, David M. Maloney, James C. Young
40th Edition
1305874331, 978-1305874336
