Questions from General Taxation

Q: Discuss the policy reasons for the existence of the Subpart F rules

Discuss the policy reasons for the existence of the Subpart F rules. Give two examples of Subpart F income.

Q: Hart Enterprises, a domestic corporation, owns 100% of OK

Hart Enterprises, a domestic corporation, owns 100% of OK, Ltd., an Irish corporation. OK’s gross income for the year is $10 million. Determine whether any of the following transactions produce Subpar...

Q: Skills, Inc., a U.S. corporation, reports

Skills, Inc., a U.S. corporation, reports current foreign-source income classified in two different FTC income baskets. It earns $50,000 in passive foreign- source income, and it suffers a net loss of...

Q: Night, Inc., a domestic corporation, earned $300,

Night, Inc., a domestic corporation, earned $300,000 from foreign manufacturing activities, on which it paid $90,000 of foreign income taxes. Night’s foreign sales income is taxed at a 50% foreign tax...

Q: Assume that the value of each share of Kingfisher stock is $

Assume that the value of each share of Kingfisher stock is $3,000. As to these transactions, provide the following information: a. Seth’s recognized gain or loss. Identify the natur...

Q: Lili, Inc., a domestic corporation, operates a branch in

Lili, Inc., a domestic corporation, operates a branch in France. The earnings record of the branch is as follows. For 2013–2016, Lili, Inc., reports U.S.-source taxable income of $5...

Q: Write a memo for the tax research file on the difference between

Write a memo for the tax research file on the difference between “inbound” and “outbound” activities in the context of U.S. taxation of international income.

Q: Warwick, Inc., a U.S. corporation, owns

Warwick, Inc., a U.S. corporation, owns 100% of NewGrass, Ltd., a foreign corporation. NewGrass earns only general limitation income. During the cur- rent year, NewGrass paid Warwick a $10,000 dividen...

Q: Evaluate this statement: A state can tax only its resident individuals

Evaluate this statement: A state can tax only its resident individuals and the corporations and partnerships that are organized in-state.

Q: You are working with the top management of one of your clients

You are working with the top management of one of your clients in selecting the U.S. location for a new manufacturing operation. Craft a plan for the CEO to use in discussions with the economic develo...