Exam 11: International Taxation

A U.S.corporation is subject to an income tax rate of 35% and has a branch in the U.K., which paid the national corporate tax rate of 30% on its earnings there.The branch generated taxable income from operations in the U.K.equivalent to $2,000,000.What is the amount of the taxes owed to the U.S.government on the income generated in the U.K.?

What is the meaning of "tax system neutrality?"

In the context of international taxation, the Bahamas, Lichtenstein, and Monaco are considered by the OEDC as:

How is a foreign subsidiary different from a foreign branch of a domestic corporation?

What explains the "follow-the-leader" effect of countries changing their corporate tax rates in response to changes made by other countries?

How does the U.S.government tax controlled foreign corporations (CFC) differently from other subsidiaries?

Under the citizenship approach of tax jurisdiction, if Company A, incorporated in Country X, was based in Country Y and earned dividends in Country Z, the dividends would be ultimately taxed in which country?

What is the U.S.policy concerning taxing income of a U.S.corporation's foreign subsidiary?

What is a major limitation to the apparent incentive of tax holidays?

What is a tax holiday?

Dividends received from companies in countries other than one's home country are classified as:

What is a withholding tax?

What is a value added tax (VAT)?

While the U.S.has tax treaties with more than 50 countries, it does not have a treaty with Brazil, which is a major recipient of U.S.foreign direct investment.What is the reason for a lack of a U.S.-Brazil treaty regarding withholding taxes?

The income of a foreign subsidiary is not taxable until dividends are distributed to the U.S.parent unless:

Under U.S.tax law, what is a "resident?"

In following the international norm concerning tax jurisdiction, how would double taxation be eliminated?

What term is used to describe a foreign corporation in which U.S.shareholders hold more than 50% of the voting power or fair market value of the corporation's stock?

A Japanese branch of a U.S. corporation paid $4,200,000 in taxes to the government of Japan on income it generated there. The corporation is subject to a 35% tax rate in the U.S. -How much foreign tax credit can be taken in calculating the taxes owed to the U.S.on $10,000,000 of Japanese branch income?

In addition to having very low effective tax rates, which of the following is also a characteristic of tax havens?