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Worldwide United Corporation (WUC), a U.S. taxpayer, manufactures and sells products through a network of foreign branches and wholly-owned foreign subsidiaries. Relevant information for these entities for the current fiscal year: the following table: Additional Information: Legal Entity Country Form Activity Income before Tax Income Tax Rate Dividend Withholding Tax Rate Net Dividend Received by Parent A Bahrain Branch Sales $1,000,000 0% 0% $1,000,000 B Bermuda Corporation Sales 8,000,000 0 0 8,000,000 C Hong Kong Corporation Manufacturing 10,000,000 16.5 0 8,350,000 D Hungary Corporation Sales 10,000,000 9 9,100,000 E Ireland Corporation Investment 2,000,000 12.5 0 1,750,000 F Malaysia Branch Manufacturing 10,000,000 24 7,600,000 G H Mexico Switzerland Corporation Corporation Manufacturing Service 5,000,000 500,000 30 5 17 35 3,3250,000 269,750 1. Entities C, F, and G manufacture products that are sold in their home countries as well as to sister entities within the WUC group. 2. Entity A purchases finished products from Entity F and then sells them throughout the Middle East. Only 5 percent of A's income is generated from sales to customers in Bahrain; 95 percent of A's income is from sales to foreign customers. 3. Entity B purchases finished products from Entity G and sells them throughout North and South America. Only 1 percent of B's income is from sales to customers in Bermuda; 99 percent of B's income is from sales to foreign customers. 4. Entity D purchases finished products from Entity C and then sells them throughout Europe. Only 40 percent of D's income is generated from sales to customers in Hungary; 60 percent of D's income is from sales to foreign customers. 5. Entity E makes passive investments in stocks and bonds in European financial markets. All of E's income is derived from dividends and interest. 6. Entity H provides accounting and other management services to WUC's other foreign operations. All of H's income is derived from providing services to sister companies within the WUC group. Required: 1. Determine the amount of U.S. taxable income for each entity (A, B, C, D, E, F, G, and H). 2. Calculate the foreign tax credit allowed in the United States, first by foreign tax credit basket and then in total. 3. Determine the net U.S. tax liability on foreign source income. 4. Determine any excess foreign tax credits and identify by basket. Worldwide United Corporation (WUC), a U.S. taxpayer, manufactures and sells products through a network of foreign branches and wholly-owned foreign subsidiaries. Relevant information for these entities for the current fiscal year: the following table: Additional Information: Legal Entity Country Form Activity Income before Tax Income Tax Rate Dividend Withholding Tax Rate Net Dividend Received by Parent A Bahrain Branch Sales $1,000,000 0% 0% $1,000,000 B Bermuda Corporation Sales 8,000,000 0 0 8,000,000 C Hong Kong Corporation Manufacturing 10,000,000 16.5 0 8,350,000 D Hungary Corporation Sales 10,000,000 9 9,100,000 E Ireland Corporation Investment 2,000,000 12.5 0 1,750,000 F Malaysia Branch Manufacturing 10,000,000 24 7,600,000 G H Mexico Switzerland Corporation Corporation Manufacturing Service 5,000,000 500,000 30 5 17 35 3,3250,000 269,750 1. Entities C, F, and G manufacture products that are sold in their home countries as well as to sister entities within the WUC group. 2. Entity A purchases finished products from Entity F and then sells them throughout the Middle East. Only 5 percent of A's income is generated from sales to customers in Bahrain; 95 percent of A's income is from sales to foreign customers. 3. Entity B purchases finished products from Entity G and sells them throughout North and South America. Only 1 percent of B's income is from sales to customers in Bermuda; 99 percent of B's income is from sales to foreign customers. 4. Entity D purchases finished products from Entity C and then sells them throughout Europe. Only 40 percent of D's income is generated from sales to customers in Hungary; 60 percent of D's income is from sales to foreign customers. 5. Entity E makes passive investments in stocks and bonds in European financial markets. All of E's income is derived from dividends and interest. 6. Entity H provides accounting and other management services to WUC's other foreign operations. All of H's income is derived from providing services to sister companies within the WUC group. Required: 1. Determine the amount of U.S. taxable income for each entity (A, B, C, D, E, F, G, and H). 2. Calculate the foreign tax credit allowed in the United States, first by foreign tax credit basket and then in total. 3. Determine the net U.S. tax liability on foreign source income. 4. Determine any excess foreign tax credits and identify by basket.
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1 Calculate US Taxable Income for Each Entity a Entity A Branch in Bahrain Income before tax 1000000 Income Tax Rate 0 Branch income typically is not ... View the full answer
Related Book For
International Accounting
ISBN: 978-1260466539
5th edition
Authors: Timothy Doupnik, Mark Finn, Giorgio Gotti, Hector Perera
Posted Date:
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