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ABC Co. was incorporated in Canada in 2015, however, it never did business in Canada. It had a permanent establishment in the US only. How will ABC be taxed?
a. taxed in Canada on its Canadian income only
b. Taxed in the US only since that is where the permanent establishment is
c. Taxed in both Canada and the US based on share of income
d. Taxed in Canada on its world income and given a foreign tax credit for any US taxes paid
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- A non-U.S. corporation investor held a real estate asset (a parcel of land) that that was purchased for $100,000,000 for 10 years and will sell it for $130,000,000. The investor gain on the sale of the asset is considered to in a business that is effectively connected to a U.S. trade or business (ECI). Compute the tax on the sale assuming that the investor held the asset directly (consider double tax - both ECI and branch profits tax) __________________ Compute the tax to the investor if held through US corporation (consider both entity level tax and FDAP tax on the distributions) with no treaty rates and a plan of liquidation in the year of sale _______________________Which of the following corporations would not be considered resident in Canada for tax purposes?1)Axem Inc. was incorporated in Manitoba on April 5, 1965 and has carried on business in Canada sincethat date. 2)Linco Ltd. was incorporated in Ontario on April 4, 1985 and, until the end of 1999,all of the operations and board of directors meetings were held in the southern United States. In 2000,all of the management and operations of the Company moved to Toronto. 3)Norad Inc. was incorporated in New York state on March 1, 1985 and, until the end of 1993, carried on business in Canada. At that time, all of the management and operations of the Company moved to the southern United States. 4)Rio Amgal Inc. was incorporated in Manitoba on September 3, 2010. While the Company hasoperations in both Canada and the U.S., the directors live in Calgary. As a consequence, all director’smeetings are held in that city. 5)In all cases the corporations would be considered residents of Canada.Why does Apple Operations International (AOI)— the Irish subsidiary that captures most of Apple’s global profits outside the Americas— not pay taxes to Ireland or the United States?
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