LO.5 Mary, a U.S. citizen, is the sole shareholder of CanCo, a Canadian corporation. During its first

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LO.5 Mary, a U.S. citizen, is the sole shareholder of CanCo, a Canadian corporation.

During its first year of operations, CanCo earns $14 million of foreign-source taxable income, pays $6 million of Canadian income taxes, and distributes a $2 million dividend to Mary. Can Mary claim a deemed-paid (indirect) FTC on her Form 1040 with respect to receipt of the dividend distribution from CanCo? Why or why not?

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South Western Federal Taxation 2013 Corporations Partnerships Estates And Trusts

ISBN: 9781133495574

36th Edition

Authors: William H. Hoffman, William A. Raabe, James E. Smith, David M. Maloney

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