Question
Wall Inc., a US corporation, owns 100% of the following subsidiaries. Floor Inc. a foreign corporation organized in Germany Ceiling Inc., a foreign corporation organized
Wall Inc., a US corporation, owns 100% of the following subsidiaries.
Floor Inc. a foreign corporation organized in Germany
Ceiling Inc., a foreign corporation organized France
Floor buys product from Wall and sells it to Ceiling. It earned pre-tax income of $5,000 on such sales and paid $1,000 of tax. Floor has no depreciable tangible assets.
Ceiling sells the product it buys from Floor to customers located in France. It earns $6,000 pre-tax income on such sales and pays $1,250 on such income. Ceiling has $1,000 of basis in its tangible depreciable assets.
What amount of Subpart F income does Wall need to include?
What is the total income inclusion Wall has to pick up assuming Wall takes a foreign tax credit?
What is Walls US tax obligation after foreign tax credits?
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