Leming, Inc. is a CFC with total foreign earnings of $90 million, of which $27 million is

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Leming, Inc. is a CFC with total foreign earnings of $90 million, of which $27 million is considered subpart F income. Leming owns tangible business property with an adjusted tax basis of $70 million. Hare Corporation, a U.S. corporation, owns 30 percent of the stock of Leming.

a. Compute Leming’s global intangible low-taxed income (GILTI).

b. Compute Hare’s pro rata share of Leming’s GILTI and subpart F income.

c. Compute Hare’s incremental U.S. tax liability as a result of its ownership of Leming.

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Principles Of Taxation For Business And Investment Planning 2019 Edition

ISBN: 9781260161472

22nd Edition

Authors: Sally Jones, Shelley C. Rhoades Catanach, Sandra R Callaghan

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