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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
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 2019, Windmill reported the following foreign source income from its international operations and investments. CanCo IrishCo KlwiCo Tulip Co $45,000 2,250 $28,000 1,400 $20,000 3,000 Dividend Income Amount Withholding tax Interest Income Amount Withholding tax Branch Income Taxable income AUS Income taxes 30,000 $93,000 31,000 Note: CanCo and KiwiCo derive all of their earnings from active business operations. a) Classify the income received by Windmill into the appropriate FTC baskets. b) Windmill has $1.250,000 of U.S. source gross income. Windmill also incurred SG&A of $300,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $200,000. Compute the FTC limitation for each basket of foreign source income. 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 2019, Windmill reported the following foreign source income from its international operations and investments. CanCo IrishCo KlwiCo Tulip Co $45,000 2,250 $28,000 1,400 $20,000 3,000 Dividend Income Amount Withholding tax Interest Income Amount Withholding tax Branch Income Taxable income AUS Income taxes 30,000 $93,000 31,000 Note: CanCo and KiwiCo derive all of their earnings from active business operations. a) Classify the income received by Windmill into the appropriate FTC baskets. b) Windmill has $1.250,000 of U.S. source gross income. Windmill also incurred SG&A of $300,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $200,000. Compute the FTC limitation for each basket of foreign source income
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