Questions from Federal Taxation

Q: Cordeio, Inc., is a CFC for the entire tax year

Cordeio, Inc., is a CFC for the entire tax year (not a leap year). Vancy Company, a U.S. corporation, owns 75% of Cordeio’s one class of stock for the entire year. Subpart F income is $450,000, and no...

Q: Klein, a domestic corporation, receives a $10,000

Klein, a domestic corporation, receives a $10,000 dividend from ForCo, a wholly owned foreign corporation. The deemed-paid FTC associated with this dividend is $3,000. What is the total gross income i...

Q: Indeco, a U.S. C corporation, operates Grange

Indeco, a U.S. C corporation, operates Grange, a sales branch in Staccato. Indeco’s U.S. corporate marginal tax rate is 35%; it is 20% for Staccato. Grange’s pre-ta...

Q: Honk, Inc., a U.S. corporation, purchases

Honk, Inc., a U.S. corporation, purchases weight-lifting equipment for resale from HiDisu, a Japanese corporation, for 60 million yen. On the date of purchase, 105 yen is equal to $1 U.S. (¥105:$1). T...

Q: Randall operates his distribution business in several countries. He wants to

Randall operates his distribution business in several countries. He wants to move some equipment to a new office in South Africa. This equipment includes assets with a large acquisition price and accu...

Q: Joy Marcus owns several income-producing assets, including a stock

Joy Marcus owns several income-producing assets, including a stock portfolio and a small services proprietorship. She wants to start up a new corporation in the country Molto, where the income tax rat...

Q: Five unrelated U.S. individuals own all of the shares

Five unrelated U.S. individuals own all of the shares of Popping, a corporation organized in the United States but operating fully in the country Vivace. Mariam, one of the shareholders, asks you whet...

Q: Sunset, Inc., a § 501(c)(3)

Sunset, Inc., a § 501(c)(3) exempt organization that is classified as a private foundation, generates investment income of $500,000 for the current tax year. This amount represents 18% of Sunset’s tot...

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: What is a guaranteed payment? How is it reported on Form

What is a guaranteed payment? How is it reported on Form 1065 and its various schedules? How is it reported to and by the partner?