Question
Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50 percent-owned joint venture,
Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50 percent-owned joint venture, CanCo. CanCo is treated as a corporation for U.S. and Canadian tax purposes. An unrelated Canadian investor owns the remaining 50 percent. Windmill conducts its operations in Ireland through a wholly owned subsidiary, IrishCo. IrishCo is a controlled foreign corporation for U.S. tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid entity, KiwiCo. KiwiCo is treated as a branch for U.S. tax purposes and a corporation for Australian tax purposes. Windmill also owns a 5 percent interest in a Dutch corporation, TulipCo. During 2021, Windmill reported the following foreign source income from its international operations and investments.
CanCo | IrishCo | KiwiCo | TulipCo | |
---|---|---|---|---|
Dividend income | ||||
Amount | $ 46,200 | $ 30,800 | $ 20,800 | |
Withholding tax | 2,310 | 1,540 | 3,120 | |
Interest income | ||||
Amount | $ 31,000 | |||
Withholding tax | 0 | 0 | ||
Branch income | ||||
Taxable income | $ 94,500 | |||
AUS income taxes | $ 31,500 |
Note: CanCo and KiwiCo derive all of their earnings from active business operations.
Requirement:
- Classify the income received by Windmill into the appropriate FTC baskets.
- Windmill has $1,252,000 of U.S. source gross income. Windmill also incurred SG&A of $302,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCos gross income is $206,700. Compute the FTC limitation for each basket of foreign source income.
Req A Req B Classify the income received by Windmill into the appropriate FTC baskets. (Leave no answer blank. Enter zero if applicable.) Gross income Passive General Totals Req A Req B Windmill has $1,252,000 of U.S. source gross income. Windmill also incurred SG&A of $302,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $206,700. Compute the FTC limitation for each basket of foreign source income. (Do not round any division. Round other intermediate computations and final answers to the nearest whole dollar amount.) Show less A Foreign tax credit limitation on passive category income Foreign tax credit limitation on general category income
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started