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Most states begin the computation of corporate taxable income with an amount from the Federal income tax return.

A) True
B) False

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Kunst,a U.S.corporation,generates $100,000 of foreign-source income in the general income basket and $40,000 of foreign-source income in the passive income basket.Kunst's worldwide taxable income is $1,200,000,and its U.S.tax liability before FTC is $420,000.Foreign taxes attributable to the general income basket are $60,000 and to the passive income are $4,000.What is Kunst's foreign tax credit for the tax year?


A) $64,000
B) $39,000
C) $35,000
D) $4,000

E) C) and D)
F) A) and D)

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Which of the following statements regarding the U.S.taxation of non-U.S.persons is true?


A) Non-U.S.persons never are subject to U.S.income tax.
B) Non-U.S.persons are subject to U.S.income tax only on gains from U.S.real property.
C) Non-U.S.persons are subject to a withholding tax on U.S.-source portfolio income.
D) Non-U.S.persons are subject to a withholding tax on foreign-source portfolio income.

E) A) and B)
F) B) and D)

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Subpart F income includes portfolio income like dividends and interest.

A) True
B) False

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A typical state taxable income addition modification is for the Federal income tax paid for the tax year.

A) True
B) False

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A unitary business applies a combined apportionment formula,including data from operations of all of the affiliates.

A) True
B) False

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The United States has in force income tax treaties with about 70 countries.

A) True
B) False

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In most states,a taxpayer's income is apportioned on the basis of a formula measuring the extent of business contact,and allocated according to the location of property owned or used.

A) True
B) False

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Performance,Inc. ,a U.S.corporation,owns 100% of Krumb,Ltd. ,a foreign corporation.Krumb earns only general basket income.During the current year,Krumb paid Performance a $200,000 dividend.The foreign tax credit associated with this dividend is $30,000.The foreign jurisdiction requires a withholding tax of 30%,so Performance received only $140,000 in cash as a result of the dividend.What is Performance's total U.S.gross income reported as a result of the $140,000 cash received?


A) $30,000
B) $140,000
C) $200,000
D) $230,000

E) B) and C)
F) B) and D)

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Which of the following statements best describes the primary purpose of the Subpart F income provisions?


A) They allow for a deferral of non-U.S.-source income from U.S.taxation.
B) They provide certainty as to the U.S.income tax treatment of cross-border transactions.
C) They prevent shifting of income from the U.S.to high-tax non-U.S.jurisdictions.
D) They prevent shifting of income from the U.S.to low-tax non-U.S.jurisdictions.

E) A) and B)
F) A) and C)

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Which of the following determinations requires knowing the amount of one's foreign-source gross income?


A) Itemized deductions.
B) Foreign tax credit.
C) Calculation of a U.S.person's total taxable income.
D) Calculation of a U.S.person's deductible interest expense.

E) A) and B)
F) B) and D)

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Wellington,Inc. ,a U.S.corporation,owns 30% of a CFC that has $50 million of earnings and profits for the current year.Included in that amount is $20 million of Subpart F income.Wellington has been a CFC for the entire year and makes no distributions in the current year.Wellington must include in gross income (before any ยง 78 gross-up) :


A) $0.
B) $6 million.
C) $20 million.
D) $50 million.

E) B) and C)
F) All of the above

Correct Answer

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The sourcing rules of Federal income taxation apply to deductions as well as to income items.

A) True
B) False

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A state can levy an income tax on a business only if the business was incorporated in the state.

A) True
B) False

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The property factor includes land and buildings used for business purposes.

A) True
B) False

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Discuss how a multistate business divides up its corporate taxable income among the states in which it operates.Hint: use the terms allocation and apportionment in your comments.

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Generally,business income is apportioned...

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All of the U.S.states use an apportionment formula based on the sales,property,and payroll factors.

A) True
B) False

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False

Britta Corporation's entire operations are located in State A.Eighty percent ($800,000) of Britta's sales are made in A and the remaining sales ($200,000) are made in State B.B has not adopted a corporate income tax.If A has adopted a throwback rule,the numerator of Britta's A sales factor is:


A) $0.
B) $200,000.
C) $800,000.
D) $1,000,000.

E) None of the above
F) A) and D)

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D

Which of the following statements best describes the purpose of ยง 482,under which the Treasury can reallocate income and deductions among related taxpayers?


A) To provide tax benefits to U.S.multinationals that export U.S.produced property.
B) To allow the IRS to select the best method for determining transfer prices for U.S.taxpayers.
C) To alleviate double taxation problems generated by related entities doing business in two or more countries.
D) To place a controlled entity on a tax parity with an uncontrolled entity with regard to prices charged by the entities.

E) A) and B)
F) A) and C)

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D

Politicians frequently use tax credits and exemptions to create economic development incentives.

A) True
B) False

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