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 US CCorporation with a calendar year end, manufactures widgets in its plant in Saugatuck, Michigan. On January Wonder forms a whollyowned subsidiary in the United Kingdom UK PilotOne Limited PilotOne which also has a calendar year end and is treated as a foreign corporation for US tax purposes. PilotOne purchases widgets manufactured in the US from its parent company Wonder, which it markets, sells, and distributions throughout the UK In calendar year PilotOne generated $ of foreignsource taxable income, under US tax principles, and paid $ of UK corporate income tax, resulting in CFC tested income of $ For the record, Wonder is not a US shareholder in any other foreign corporation. Also, for calendar year PilotOnes Qualified Asset Business Investment QABI was $ Neither Wonder or PilotOne incurred any interest expense; ie both companies are debtfree. In calendar year Wonders deduction eligible income DEI was $ and its foreignderived deduction eligible income FDDEI was $ Also, for calendar year Wonders Qualified Asset Business Investment QABI was $ Assume that Wonders corporate income tax return only includes deduction eligible income and its Global Intangible LowTaxed Income GILTI inclusion from PilotOne, plus the IRC Section grossup for foreign taxes paid. Furthermore, no deductible USbased expenses are allocated and apportioned against the GILTI inclusion. Also, assume the flat US corporate income tax rate is percent. a Calculate Wonders Global Intangible LowTaxed Income GILTI inclusion. pointsb Calculate Wonders ForeignDerived Intangible Income FDII deduction. pointsc Calculate Wonders US taxable income and the US residual tax, if any, due after taking an IRC Section deemed foreign tax credit. points
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