Question: Please help me and answer all questions 21. An advance pricing agreement (APA) is used between: a. Two or more governments. b. Two related taxpayers.

Please help me and answer all questions

21. An advance pricing agreement (APA) is used between:

a. Two or more governments.

b. Two related taxpayers.

c. The taxpayer and the IRS.

d. The IRS and non- U.S. non-taxing authorities

22. A controlled foreign corporation (CFC) realizes Subpart F income from:

a. Purchase of inventory from an unrelated U.S. person and sale outside the CFC country.

b. Purchase of inventory from a related U.S. person and sale outside the CFC country.

c. Services performed for the U.S. parent in a country in which the CFC was organized.

d. Services performed on behalf of an unrelated party in a country outside the country in which the CFC was organized.

23. Which of the following statements regarding the U.S. taxation of non-U.S. persons is true?

a. A non-U.S. persons effectively connected U.S. business income is taxed by the United States only if it is portfolio income.

b. A non-U.S. persons effectively connected U.S. business income is subject to U.S. income taxation.

c. A non-U.S. person may earn income from selling U.S. real property without incurring any U.S. income tax under any circumstances.

d. A non-U.S. person must spend at least 10 days in the United States before any effectively connected income is subject to U.S. taxation.

24. A Controlled Foreign Corporation is a subsidiary in which the U.S. shareholder owns more than

a. 10% of the voting power of the entity

b. 25% of the voting power of the entity

c. 50% of the voting power of the entity

d. 75% of the voting power of the entity

25. A U.S. Shareholder is a person who owns more than:

a. 10% of the of voting stock of the foreign corporation.

b. 20% of the of voting stock of the foreign corporation.

c. 30% of the of voting stock of the foreign corporation.

d. 40% of the of voting stock of the foreign corporation

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