Exam 13: Jurisdictional Issues in Business Taxation

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Which of the following could result in a corporation having more than 100% of its income subject to state taxation?

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The foreign tax credit can reduce a corporation's alternative minimum tax.

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Columbus Inc. owns 100 percent of the stock of Spania, a foreign corporation. All of Spania's income is foreign source, and its foreign income tax rate is 20 percent. This year, Spania distributed a $100,000 dividend to Columbus. a. Assuming that Columbus is in the 35 percent tax bracket, compute its U.S. tax on the dividend. b. How would your computation change if Spania's foreign income tax rate was 45 percent?

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Tradewinds is a Bermuda corporation that is 100% owned by Larkin, a U.S. corporation. Which of the following transactions generates subpart F income for U.S. tax purposes?

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Foreign value-added taxes and excise taxes are eligible for the U.S. foreign tax credit.

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This year, Sutton Corporation's before-tax income was $2,000,000. It paid $175,000 income tax to Nebraska and $300,000 income tax to Iowa. Compute Sutton's federal income tax.

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

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Transfer prices cannot be used by U.S. corporations and their foreign affiliates to shift income between taxing jurisdictions.

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Which of the following statements concerning the nexus required for a state to tax income is false?

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Jenkin Corporation reported the following for its first two taxable years. Jenkin Corporation reported the following for its first two taxable years.   Calculate Jenkin's U.S. tax liability for Year 2. Calculate Jenkin's U.S. tax liability for Year 2.

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Southern, an Alabama corporation, has a $7 million excess FTC carryforward attributable to its foreign branch manufacturing operations. Which of the following strategies should increase Southern's use of its FTC carryforward to reduce U.S. tax?

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Which of the following statements about the foreign tax credit limitation is false?

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Logan, an Indiana corporation, conducts its international business through 100% controlled foreign subsidiaries. This year, Logan's U.S. source taxable income was $5,431,000, and it received $12,250,000 dividends from its foreign subsidiaries. Logan paid no foreign income tax itself, but its subsidiaries paid foreign income tax at a 30% rate. Logan's U.S. income tax (35% rate) is:

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Albany, Inc. does business in states C and D. State C uses an apportionment formula that double-weights the sales factor; state D apportions income using an equally-weighted three-factor formula. Albany's before tax income is $3,000,000, and its sales, payroll, and property factors are as follows.

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Economic nexus:

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Which of the following statements about subpart F income is false?

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The Quad affiliated group consists of Quad, a Delaware corporation, and its three wholly-owned subsidiaries. This year, the four corporations report the following net income (loss). The Quad affiliated group consists of Quad, a Delaware corporation, and its three wholly-owned subsidiaries. This year, the four corporations report the following net income (loss).   If Quad elects to file a consolidated U.S. tax return, compute consolidated taxable income assuming that subsidiaries 1 and 2 are domestic corporations and subsidiary 3 is a foreign corporation. If Quad elects to file a consolidated U.S. tax return, compute consolidated taxable income assuming that subsidiaries 1 and 2 are domestic corporations and subsidiary 3 is a foreign corporation.

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Tri-State's, Inc. operates in Arkansas, Oklahoma, and Kansas. Assume that each state has adopted the UDITPA formula. During the corporation's tax year ended December 31, the apportionment data indicated: Tri-State's, Inc. operates in Arkansas, Oklahoma, and Kansas. Assume that each state has adopted the UDITPA formula. During the corporation's tax year ended December 31, the apportionment data indicated:   Which of the following statements is true? Which of the following statements is true?

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The foreign tax credit is available for both income and property taxes paid to a foreign jurisdiction.

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Global Corporation, a U.S. multinational, began operations this year. Global had pretax U.S. source income and foreign source income as follows. Global Corporation, a U.S. multinational, began operations this year. Global had pretax U.S. source income and foreign source income as follows.   Global paid $25,000 income tax to Country X. What is Global's U.S. tax liability if it takes the foreign tax credit? Global paid $25,000 income tax to Country X. What is Global's U.S. tax liability if it takes the foreign tax credit?

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