Question: Wonder World, Inc. ( Wonder ) , a U . S . C - Corporation with a calendar year end, manufactures widgets in its plant

Wonder World, Inc. (Wonder), a U.S. C-Corporation with a calendar year end, manufactures widgets in its plant in Saugatuck, Michigan. On January 1,2024, Wonder forms a wholly-owned subsidiary in the United Kingdom (UK), PilotOne Limited (PilotOne), which also has a calendar year end and is treated as a foreign corporation for U.S. tax purposes. PilotOne purchases widgets (manufactured in the U.S.) from its parent company Wonder, which it markets, sells, and distributions throughout the UK. In calendar year 2024, PilotOne generated $2,500,000 of foreign-source taxable income, under U.S. tax principles, and paid $450,000 of U.K. corporate income tax, resulting in CFC tested income of $2,050,000. For the record, Wonder is not a U.S. shareholder in any other foreign corporation. Also, for calendar year 2024, PilotOnes Qualified Asset Business Investment (QABI) was $500,000. Neither Wonder or PilotOne incurred any interest expense; i.e., both companies are debt-free. In calendar year 2024, Wonders deduction eligible income (DEI) was $120,000,000, and its foreign-derived deduction eligible income (FDDEI) was $24,000,000. Also, for calendar year 2024, Wonders Qualified Asset Business Investment (QABI) was $800,000,000. Assume that Wonders 2024 corporate income tax return only includes deduction eligible income and its Global Intangible Low-Taxed Income (GILTI) inclusion from PilotOne, plus the IRC Section 78 gross-up for foreign taxes paid. Furthermore, no deductible U.S.-based expenses are allocated and apportioned against the GILTI inclusion. Also, assume the flat U.S. corporate income tax rate is 21 percent. (a.) Calculate Wonders Global Intangible Low-Taxed Income (GILTI) inclusion. (2 points)(b.) Calculate Wonders Foreign-Derived Intangible Income (FDII) deduction. (2 points)(c.) Calculate Wonders U.S. taxable income and the U.S. residual tax, if any, due after taking an IRC Section 960 deemed foreign tax credit. (2 points)

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