Please complete the homework problems found below. These will help you to apply the concepts you have learned from the readings. They require you to think critically and perform tax research to derive a response or solution to a proposed tax issue. You can utilize CCH AnswerConnect from the Purdue University Global Library to perform your research.

1. US tax law has various anti-deferral regimes to prevent taxpayers from deferring or avoiding US taxation by shifting income to a foreign base company or holding earnings in foreign subsidiaries since generally those earnings are not subject to US tax until they are repatriated back to the US in the form of a dividend. Briefly explain each of the following topics. Include an explanation of the reason for each regime, how earnings in each category are taxed, and the rate at which those earnings are taxed.
   1. Subpart F Income
   2. GILTI
   3. FDII
   4. PFIC Income
2. Motor Inc., a U.S. corporation, produces industrial engines at its U.S. plant for sale in the United States and Canada. During the current year, Motor Inc.'s total sales to Canadian customers are $20 million and the related cost of goods sold is $14 million. Title passes in Canada on all engine sales to Canadian customers.
   1. How much of Motor Inc.'s export gross profit of $6 million (export sales of $20 million less $14 million cost of goods sold) is classified as foreign-source for U.S. tax purposes?
   2. Now assume that the facts are the same as in part (a), except that Motor Inc. is a distributor that purchases the engines from independent third parties for sale to customers in both the United States and Canada. How much of Motor Inc.'s export gross profit of $6 million from Canadian sales is classified as foreign-source for U.S. tax purposes?
3. Jimner was born in El Salvador but moved to the United States as a child. He holds a green card and has not visited El Salvador for more than 20 years. However, Jimner received four types of income from El Salvador. He sold a parcel of land in El Salvador that he inherited years ago from a deceased grandparent and realized a gain on the sale. He received royalties from an oil and gas company that extracted oil from another inherited property in El Salvador. He received a dividend from a UK based company, Phoneco Inc., which has an office in El Salvador. In addition, he received interest on a loan he gave to his childhood friend who also immigrated to the US as a child. His friend has dual citizenship, but has resided in the US for over 20 years. The United States does not have an income tax treaty with El Salvador.Apply the income sourcing rules and determine whether each of the four types of income are US-source or foreign-source.
4. Under international tax law, what are the general rules for assigning expenses to certain sources of income?
5. Use AnswerConnect to answer the following questions:
   1. How is a resident of Bermuda defined in its treaty with the United States?
   2. How does Azerbaijan deal with intercompany transfer pricing?
   3. What is the title of article 20 in the 2017 OECD Model Tax Convention on Income and Capital?