Exam 13: Jurisdictional Issues in Business Taxation

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Economic nexus:

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Harris Corporation's before-tax income was $400,000. It does business entirely in Pennsylvania, which has a 6% corporate income tax. Compute Harris' federal income tax.

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Korn, Co. was incorporated in Delaware. It has production, distribution, and sales facilities in Kansas and Nebraska. All of Korn's customers reside in Kansas or Nebraska. Assume that both states use the UDITPA formula for apportionment of income. The corporation is investing in new equipment that cost $900,000. The equipment could be used in either the Kansas or Nebraska production facilities. Assume that Kansas' corporate income tax rate is 7% and Nebraska's is 8.5%. Should the equipment be placed in Kansas or Nebraska to minimize Korn's state income tax?

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The United States has jurisdiction to tax income earned by any foreign corporation that is a controlled subsidiary of a U.S. parent corporation.

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Many Mountains, Inc. is a U.S. multinational corporation. This year, it had the following income. U.S. source income \5 80,000 Eoreign source income: Country x \6 5,000 Country Y 105,000 170,000 Total \7 50,000 Many Mountains paid $15,000 income tax to Country X and $18,500 income tax to Country Y. Assume Many Mountains' foreign source income does not qualify as foreign-derived intangible income. Compute Many Mountains' allowable foreign tax credit.

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Chester, Inc., a U.S. multinational, earned $4 million this year from both domestic and international operations. Of this amount, $1.3 million qualifies as foreign-derived intangible income (FDII). If Chester pays no foreign income tax, compute its worldwide tax burden as a percentage of its pretax income.

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A foreign branch operation of a U.S. corporation is not a separate legal entity.

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