Question
USA Corp, a calendar year domestic corporation, owns 30 percent of the stock of XYZ Corp, a calendar year specified foreign corporation. Prior to 2018,
USA Corp, a calendar year domestic corporation, owns 30 percent of the stock of XYZ Corp, a calendar year specified foreign corporation.
Prior to 2018, XYZ has accumulated deferred foreign earnings of $300,000 million and an aggregate foreign cash position of $25,000. Assume Malik paid zero foreign tax on its earnings.
a. Calculate the mandatory inclusion amount for USA with respect to XYZs deferred foreign earnings and the pro rata share of XYZ's foreign cash position.
b. Calculate the tax liability on its mandatory inclusion amount.
c. Determine USA's installment payments of the tax liability on its mandatory inclusion amount.
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