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Exam 25: Taxation of International Transactions

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Question 61

Multiple Choice

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Liang, an NRA, is sent to the United States by Fulston Corporation, her non-U.S. employer. She spends 50 days in the United States and earns $20,000 for a two-month period. This amount is attributable to 40 U.S. working days and 10 non-U.S. working days. Fulston does not have a United States trade or business, and Liang spends no other time in the United States for the tax year. Liang's U.S.-source taxable income is:

A) $20,000.
B) $16,000.
C) $3,000.
D) $0.

E) All of the above
F) B) and D)

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Question 62

Multiple Choice

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Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. -Portfolio income treated as Subpart F income.

A) Foreign base company income
B) Foreign personal holding company income
C) Controlled foreign corporation
D) U.S. shareholder
E) Previously taxed income
F) More than 10 percent
G) More than 50 percent
H) More than 80 percent

I) A) and C)
J) B) and F)

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Question 63

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Serena, a nonresident alien, is employed by GlobalCo, a non-U.S. corporation. She works in the United States for three days during the year, receiving a gross salary of $2,500 for this period. GlobalCo is not engaged in a U.S. trade or business. Under the commercial traveler exception, the $2,500 is not classified as U.S.-source income.

Luisa, a non-U.S. person with a green card, spends the following days in the United States. Year $1 \quad 360$ days Year $2 \quad 210$ days Year $3 \quad 30$ days Luisa's residency status for year 3 is:

Zhang, an NRA who is not a resident of a treaty country, receives taxable dividends of $50,000 from U.S. corporations. Zhang does not conduct a U.S. trade or business. Zhang's dividends are subject to withholding by the payor of:

During the current year, USACo (a domestic corporation) sold equipment to FrenchCo, a non-U.S. corporation, for $350,000 with title passing to the buyer in France. USACo purchased the equipment several years ago for $100,000 and took $80,000 of depreciation deductions on the equipment, all of which were allocated to U.S.-source income. USACo's adjusted basis in the equipment is $20,000 on the date of sale. What is the sourcing of the $330,000 gain on the sale of this equipment?

A controlled foreign corporation (CFC) realizes Subpart F income from:

Match the definition with the correct term. -Income of foreign person taxed through filing of a U.S. tax return with deductions allowed against gross income.

A U.S. taxpayer may take a current FTC equal to the greater of the FTC limit or the actual foreign taxes (direct or indirect) paid or accrued.

Peanut, Inc., a U.S. corporation, receives $500,000 of foreign-source interest income on which foreign taxes of $5,000 are withheld. Peanut's worldwide taxable income is $900,000, and its U.S. Federal income tax liability before FTC is $189,000. What is Peanut's foreign tax credit?

U.S. income tax treaties:

Julio, a nonresident alien, realizes a gain on the sale of commercial real estate located in Omaha. The real estate was sold to Mariana, Julio's cousin who is also a nonresident alien. Julio recognizes foreign-source income from the sale because his home country is not the United States.

Carol, a citizen and resident of Adagio, reports gross income that is effectively connected with a U.S. business. No deductions are allowed against this income, and Carol's U.S. tax rate is a flat 30%.

Match the definition with the correct term. -A business operation that accounts for profits and losses using its functional currency.

Flapp Corporation, a U.S. corporation, conducts all of its transactions in the U.S. dollar. It sells inventory for $1 million to a Canadian company when the exchange rate is $1US: $1.2Can. The Canadian company pays for the inventory when the exchange rate is $1US: $1.3Can. What is Flapp's exchange gain or loss on this sale?

In which of the following independent situations would Slane, a foreign corporation, be classified as a controlled foreign corporation? The Slane stock is directly owned 12% by Jen, 10% by Kathy, 12% by Leslie, 10% by David, 8% by Ben, and 48% by Mike.

Which of the following statements regarding the U.S. taxation of non-U.S. persons is true?

WorldCo, a foreign corporation not engaged in a U.S. trade or business, receives $50,000 in interest income from deposits with the foreign branch of a U.S. bank. The U.S. bank earns 78% of its income from foreign sources. How much of WorldCo's interest income is U.S. source?

The IRS can use § 482 reallocations to ensure that transactions between related parties are properly reflected in a tax return.

Match the definition with the correct term. -A non-U.S. citizen who holds a "green card."