Assume in 2023, a domestic corporation P, a C corporation, directly owns two CFCs, CFC 1 and
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Assume in 2023, a domestic corporation P, a C corporation, directly owns two CFCs, CFC 1 and CFC 2. Assume CFC 1 has $700 million in tested income, with a Qualified Business Asset Investment (“QBAI”) of $150 million. CFC 2 has a tested loss of $300 million and QBAI for that year of $90 million. Assume there are no potential foreign tax credits available from CFC 1 and CFC 2. Also assume there is no interest expense incurred by CFC 1 and CFC 2. Please calculate the federal income of P resulting from the GILTI provision in 2023.
Related Book For
Income Tax Fundamentals 2013
ISBN: 9781285586618
31st Edition
Authors: Gerald E. Whittenburg, Martha Altus Buller, Steven L Gill
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