Question 1

Wellington,Inc.,a U.S.corporation,owns 30% of a CFC that has $50 million of earnings and profits for the current year.Included in that amount is $20 million of Subpart F income.Wellington has been a CFC for the entire year and makes no distributions in the current year.Wellington must include in gross income (before any § 78 gross-up) :

Accepted Answer

A)  $0.
B)  $6 million.
C)  $20 million.
D)  $50 million.E) B) and D)
F) None of the above

Question 2

Fulton,Ltd.,a foreign corporation,operates a U.S.branch that reports effectively connected U.S.earnings and profits (after income taxes)  of $800,000 for the tax year.The branch's U.S.net equity at the beginning of the tax year is $2 million and at the end of the tax year is $1.5 million.Fulton is organized in a nontreaty country.Fulton's dividend equivalent amount for the year is:

Accepted Answer

A)  $1,300,000.
B)  $800,000.
C)  $500,000.
D)  $300,000.E) B) and D)
F) A) and B)

Question 3

Chang,an NRA,is employed by Fisher,Inc.,a foreign corporation.In November,Chang spends 10 days in the United States performing consulting services for Fisher's U.S.branch.She earns $5,000 per month.A month includes 20 workdays.

Accepted Answer

A)  Chang has $2,500 U.S.-source income which is exempt from U.S. taxation, because she is in the U.S. for 90 days or less.
B)  Chang has $2,500 U.S.-source income which is exempt from U.S. taxation, because the amount paid to her is less than $3,000.
C)  Chang has $2,500 U.S.-source income, because her foreign employer has a U.S. branch.
D)  Chang has no U.S.-source income, under the commercial traveler exception.E) A) and D)
F) B) and C)

Question 4

An advance pricing agreement (APA)  is used between:

Accepted Answer

A)  Two or more governments.
B)  Two related taxpayers.
C)  The taxpayer and the IRS.
D)  The IRS and U.S. taxing authorities.E) A) and C)
F) C) and D)

Exam 25: Taxation of International Transactions

Chang,an NRA,is employed by Fisher,Inc.,a foreign corporation.In November,Chang spends 10 days in the United States performing consulting services for Fisher's U.S.branch.She earns $5,000 per month.A month includes 20 workdays.

Correct Answer
verified

An advance pricing agreement (APA) is used between:

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Exam 25: Taxation of International Transactions

Chang,an NRA,is employed by Fisher,Inc.,a foreign corporation.In November,Chang spends 10 days in the United States performing consulting services for Fisher's U.S.branch.She earns $5,000 per month.A month includes 20 workdays.

Correct AnswerverifiedShow Answer

An advance pricing agreement (APA) is used between:

Correct AnswerverifiedShow Answer

Correct AnswerverifiedShow Answer

Correct AnswerverifiedShow Answer

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified