Question 1

Generally, accrued foreign income taxes are translated at the:

Accepted Answer

A)   Exchange rate when the taxes are paid.
B)   Exchange rate on the date when the taxes are accrued.
C)   Average exchange rate for the tax year to which the taxes relate.
D)   Average exchange rate for the last five tax years.E) All of the above
F) C) and D)

Question 2

Magdala is a citizen of Italy and does not have permanent resident status in the United States. During the last three years she has spent a number of days in the United States: Current year - 120 days First prior year - 150 days Second prior year - 150 days
Is Magdala treated as a U.S. resident for the current year?

Accepted Answer

A)   Yes, because Magdala was present in the United States at least 31 days during the current year and 195 days during the current and prior two years (using the appropriate fractions for the prior years) .
B)   No, because Magdala is a citizen of Italy.
C)   No, because Magdala was not present in the United States at least 183 days during the current year.
D)   No, because although Magdala was present in the United States at least 31 days during the current year, she was not present at least 183 days in a single year during the current or prior two years.E) C) and D)
F) All of the above

Question 3

Nico lives in California. She was born in Peru but holds a green card. Nico is a nonresident alien (NRA).

Accepted Answer

A) True 
 B)False

Question 4

A "U.S. shareholder" for purposes of CFC classification is any U.S. person who owns directly, indirectly, and constructively at least 50% of the voting power of a foreign corporation.

Accepted Answer

A) True 
 B)False

Question 5

The sourcing rules of Federal income taxation apply to deductions as well as to income items.

Accepted Answer

A) True 
 B)False

Question 6

The purpose of the transfer pricing rules is to ensure that taxpayers have ultimate flexibility in shifting profits between related entities.

Accepted Answer

A) True 
 B)False

Exam 25: Taxation of International Transactions

The sourcing rules of Federal income taxation apply to deductions as well as to income items.

Correct Answer
verified

Nico lives in California. She was born in Peru but holds a green card. Nico is a nonresident alien (NRA).

Correct Answer
verified

Generally, accrued foreign income taxes are translated at the:

Correct Answer
verified

The purpose of the transfer pricing rules is to ensure that taxpayers have ultimate flexibility in shifting profits between related entities.

Correct Answer
verified

Correct Answer
verified

A "U.S. shareholder" for purposes of CFC classification is any U.S. person who owns directly, indirectly, and constructively at least 50% of the voting power of a foreign corporation.

Correct Answer
verified

Exam 25: Taxation of International Transactions

The sourcing rules of Federal income taxation apply to deductions as well as to income items.

Correct AnswerverifiedShow Answer

Nico lives in California. She was born in Peru but holds a green card. Nico is a nonresident alien (NRA).

Correct AnswerverifiedShow Answer

Generally, accrued foreign income taxes are translated at the:

Correct AnswerverifiedShow Answer

The purpose of the transfer pricing rules is to ensure that taxpayers have ultimate flexibility in shifting profits between related entities.

Correct AnswerverifiedShow Answer

Correct AnswerverifiedShow Answer

A "U.S. shareholder" for purposes of CFC classification is any U.S. person who owns directly, indirectly, and constructively at least 50% of the voting power of a foreign corporation.

Correct AnswerverifiedShow Answer

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified