Diagram the creation of an investment subsidiary in Delaware, by Parent, a Massachusetts corporation conducting all of its current sales activities through a single subsidiary, Junior, Inc.
Explain the purpose of determining whether a foreign person is engaged in a U.S. trade or business.
Write a short memo on the difference between ‘‘inbound’’ and ‘‘outbound’’ activities in the context of U.S. taxation of international income. Lynch’s share of her S corporation’s net operating loss is $41,000, but her stock basis is only $29,000.
Point out any tax consequences to Lynch.
Lili, Inc., a domestic corporation, operates a branch in France. The earnings CRITICAL THINKING record of the branch is as follows. For 2008–2011, Lili, Inc., has U.S.-source taxable income of $500,000 each year.
What is the allowed FTC for 2011? Assume a 35% U.S. tax rate.
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