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Windmill Corporation manufactures products in its plants in lowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50 percent-owned joint
Windmill Corporation manufactures products in its plants in lowa, 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 US 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 US tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid entity, KiwiCo. KiwiCo is treated as a branch for US 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 Check my work Canto Dividend incone Amount Withholding tax Interest Incone Amount Withholding tex Branch income Taxable income Aus income taxes $64,200 3,210 $ 40,000 $ 72,800 3.640 $ 32,000 4,920 5117,000 539.000 Note: CanCo and KiwiCo derive all of their earnings from active business operations Requirement: a. Classify the income received by Windmill into the appropriate FTC baskets b. Windmill has $1.282.000 of U.S. source gross income. Windmill also incurred SG&A of $332,000 that is apportioned between US and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $307,200 Compute the FTC imitation for each basket of foreion source income E Next
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