Question 1

Kipp, a U.S. shareholder under the CFC provisions, owns 40% of a CFC. If the CFC's Subpart F income for the taxable year is $200,000, Kipp is taxed on receipt of a constructive dividend of $80,000.

Accepted Answer

A) True 
 B)False

Question 2

Dividends received from Murdock Corp., a corporation organized in Sustenato that earns 70% of its income from
U.S. business activities, are 70% U.S.-source income.

Accepted Answer

A) True 
 B)False

Question 3

Chang, an NRA, is employed by Fisher, Inc., a foreign corporation. In November, Chang spends 10 days in the United States performing consulting services for Fisher's U.S. branch. She earns $5,000 per month. A month includes 20 workdays.

Accepted Answer

A)   Chang has $2,500 U.S.-source income, which is exempt from U.S. taxation, because she is in the United States for 90 days or less.
B)   Chang has $2,500 U.S.-source income, which is exempt from U.S. taxation, because the amount paid to her is less than $3,000.
C)   Chang has $2,500 U.S.-source income, because her foreign employer has a U.S. branch.
D)   Chang has no U.S.-source income under the commercial traveler exception.E) A) and B)
F) A) and C)

Question 4

Match the definition with the correct term.
-Method for sourcing income and deductions.

Accepted Answer

A)  Inbound
B)  Outbound
C)  Allocation and apportionment
D)  Qualified business unit
E)  Tax havenF) Income tax treaty G)  Section 482H) D) and G)
I) A) and B)

Question 5

LocalCo merges into HeirCo, a non-U.S. entity, in a transaction that would qualify as a "Type A" reorganization.
The resulting realized gain is tax-deferred under U.S. income tax law using §§ 351 and 368.

Accepted Answer

A) True 
 B)False

Question 6

Which of the following statements regarding a non-U.S. person's U.S. tax consequences is true?

Accepted Answer

A)   Non-U.S. persons may be subject to U.S. withholding tax on U.S.-source investment income.
B)   Non-U.S. individuals may be subject to U.S. income tax but non-U.S. corporations are never subject to U.S. income tax.
C)   Non-U.S. persons are subject to U.S. income or withholding tax only if engaged in a U.S. trade or business.
D)   Non-U.S. persons must be physically present in the United States before any U.S.-source income is subject to U.S. income or withholding tax.E) B) and D)
F) None of the above

Question 7

Interest paid to an unrelated party by a domestic corporation that historically earns more than 50% of its gross income each year from the conduct of an active trade or business outside the United States is foreign-source income.

Accepted Answer

A) True 
 B)False

Question 8

Given the following information, determine whether Greta, an alien, is a U.S. resident for year 3. Greta cannot establish a tax home in or a closer connection to a foreign country. $$\begin{array}{l}
\text { Year Number of Days in the United States }\
\begin{array} { l l } 
3 & 120 \
2 & 150 \
1 & 240
\end{array}
\end{array}$$

Accepted Answer

In general, for Federal income tax purpo...

Exam 25: Taxation of International Transactions

Dividends received from Murdock Corp., a corporation organized in Sustenato that earns 70% of its income from U.S. business activities, are 70% U.S.-source income.

Correct Answer
verified

Chang, an NRA, is employed by Fisher, Inc., a foreign corporation. In November, Chang spends 10 days in the United States performing consulting services for Fisher's U.S. branch. She earns $5,000 per month. A month includes 20 workdays.

Correct Answer
verified

Interest paid to an unrelated party by a domestic corporation that historically earns more than 50% of its gross income each year from the conduct of an active trade or business outside the United States is foreign-source income.

Correct Answer
verified

Kipp, a U.S. shareholder under the CFC provisions, owns 40% of a CFC. If the CFC's Subpart F income for the taxable year is $200,000, Kipp is taxed on receipt of a constructive dividend of $80,000.

Correct Answer
verified

Which of the following statements regarding a non-U.S. person's U.S. tax consequences is true?

Correct Answer
verified

Correct Answer
verified
In general, for Federal income tax purpo...
View Answer

Match the definition with the correct term. -Method for sourcing income and deductions.

Correct Answer
verified

LocalCo merges into HeirCo, a non-U.S. entity, in a transaction that would qualify as a "Type A" reorganization. The resulting realized gain is tax-deferred under U.S. income tax law using §§ 351 and 368.

Correct Answer
verified

Exam 25: Taxation of International Transactions

Dividends received from Murdock Corp., a corporation organized in Sustenato that earns 70% of its income from U.S. business activities, are 70% U.S.-source income.

Correct AnswerverifiedShow Answer

Chang, an NRA, is employed by Fisher, Inc., a foreign corporation. In November, Chang spends 10 days in the United States performing consulting services for Fisher's U.S. branch. She earns $5,000 per month. A month includes 20 workdays.

Correct AnswerverifiedShow Answer

Interest paid to an unrelated party by a domestic corporation that historically earns more than 50% of its gross income each year from the conduct of an active trade or business outside the United States is foreign-source income.

Correct AnswerverifiedShow Answer

Kipp, a U.S. shareholder under the CFC provisions, owns 40% of a CFC. If the CFC's Subpart F income for the taxable year is $200,000, Kipp is taxed on receipt of a constructive dividend of $80,000.

Correct AnswerverifiedShow Answer

Which of the following statements regarding a non-U.S. person's U.S. tax consequences is true?

Correct AnswerverifiedShow Answer

Correct AnswerverifiedIn general, for Federal income tax purpo...View AnswerShow Answer

Match the definition with the correct term. -Method for sourcing income and deductions.

Correct AnswerverifiedShow Answer

LocalCo merges into HeirCo, a non-U.S. entity, in a transaction that would qualify as a "Type A" reorganization. The resulting realized gain is tax-deferred under U.S. income tax law using §§ 351 and 368.

Correct AnswerverifiedShow Answer

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified

Correct Answer
verified
In general, for Federal income tax purpo...
View Answer

Correct Answer
verified

Correct Answer
verified