Question
Win, a U.S. manufacturing corporation, is planning to build a new production facility, and has narrowed down the possible sites for this new plant to
Win, a U.S. manufacturing corporation, is planning to build a new production facility, and has narrowed down the possible sites for this new plant to either Country A (a low-tax foreign country) or Country B (a high-tax foreign country). Win will organize the new entity owning the facility as a wholly-owned foreign subsidiary, WinFco, and finance it solely with an equity investment. Win projects that WinFcos results during its first year of operations will be as follows:
Sales..................................................................................... $200,000
Cost of goods sold................................................................ ($145,000)
Selling, general, and administrative expenses........................ ($30,000)
Income before income taxes.................................................... $25,000
Assume Country As tax rate is 10%, the United States corporate tax rate is 21%, and Country Bs rate is 30%. Further assume that neither Country A nor Country B imposes withholding taxes on interest or royalty payments paid by a local subsidiary to its U.S. parent company. Compute the total tax rate (United States plus foreign) on WinFcos profits under the following assumptions:
- The new production facility is located in Country A.
- The new production facility is located in Country B.
- The new production facility is located in Country B, but Win decides to finance WinFco with both debt and equity, such that WinFco will pay Win $12,000 of interest each year. Biz will also charge WinFco an annual royalty of $5,000 for the use of WinFcos patents and trade secrets.
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