Calabra, S.A., a Peruvian corporation, manufactures inventory in Peru. The inventory is sold to independent distributors in the United States, with title passing to the purchaser in the United States. Calabra has no employees or operations within the United States. All sales activities are conducted via telephone and Internet communication between Calabra's home office and its U.S. customers. Explain whether Calabra incurs any income effectively connected with a U.S. trade or business.
Answer to relevant QuestionsClario, S.A., a Peruvian corporation, manufactures furniture in Peru. It sells the furniture to independent distributors in the United States. Because title to the furniture passes to the purchasers in the United States, ...John McPherson is single, an attorney, and a U.S. citizen. He recently attended a seminar where he learned he could give up his U.S. citizenship, move to Bermuda (where he would pay no income tax), and operate his law ...Cordeio, Inc. is a CFC for the entire tax year. Vancy Company, a U.S. corporation, owns 75% of Cordeio's one class of stock for the entire year. Subpart F income is $450,000, and no distributions have been made during the ...Henrietta transfers cash of $75,000 and equipment with a fair market value of $25,000 (basis to her as a sole proprietor, $10,000) in exchange for a 40% profit and loss interest worth $100,000. a. How much are Henrietta's ...Jokan contributes a nondepreciable asset to the Mahali LLC in exchange for a one-fourth (25%) interest in the capital, profits, and losses of the LLC. The asset has an adjusted tax basis to Jokan and the LLC of $60,000 and a ...
Post your question