Valley View Inc., a U.S. corporation, formed a wholly owned Mexican corporation to conduct manufacturing and selling
Valley View Inc., a U.S. corporation, formed a wholly owned Mexican corporation to conduct manufacturing and selling operations in Mexico. In its first year of operations, the Mexican corporation reported taxable income of Mex$5,000,000 and paid Mexican income tax of Mex$1,500,000 on its taxable income. In the second year of its operations, the Mexican subsidiary pays a dividend of Mex$2,000,000 to Valley View, Inc. The dividend is subject to a 10 percent withholding tax (Mex$200,000) under the U.S.–Mexico treaty. Assume the currency translation rate for both years is Mex$1:US$0.05.
a). Assuming that Valley View Inc.’s Mexican subsidiary does not have any subpart F income or global intangible low-tax income (GILTI), how much taxable income would Valley View, Inc., report in U.S. dollars from its Mexican subsidiary’s first year of operations?
b). How much of the dividend from the Mexican subsidiary is subject to U.S. taxation?
c). If Valley View, Inc. only held 5 percent of the Mexican corporation stock, how much of the dividend from the Mexican corporation would be subject to U.S. taxation, and would any of the Mexican taxes imposed on the income distributed be creditable in the U.S.?