Molly, Inc., a domestic corporation, generates income from the receipt of royalty income from patents that it
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Molly, Inc., a domestic corporation, generates income from the receipt of royalty income from patents that it owns. Molly wants to avoid U.S. income tax on these royalties, so it has its 100%-owned subsidiary, based in Nigeria, hold the patents and collect the royalties.
What U.S. income tax issues must be considered in assessing this arrangement by Molly, Inc.?
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Related Book For
South-Western Federal Taxation 2020 Comprehensive
ISBN: 9780357109144
43rd Edition
Authors: David M. Maloney, William A. Raabe, James C. Young, Annette Nellen, William H. Hoffman
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