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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