U.S. corporations are eligible for a foreign tax credit for withholding taxes imposed on dividends received from 100 percent owned foreign corporations, even if the dividend qualifies for the 100 percent dividends received deduction.  True or Fal

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 _______________________

2. Liang Corporation, a U.S. entity, owns 100% of ForCo, a non-U.S. corporation not engaged in a U.S. trade or business. Is Liang subject to any U.S. income tax on her dealings with ForCo? Explain.

Castor & Pollux Limited is an Australian firm whose shares trade on the ASX. The firm earn part of its domestically income in Australia and and part of its income overseas, where it is required to pay tax to the foreign governments where it operates. Currently, the Australian corporate tax rate is 25% and the Medicare levy is 2%. Castor & Pollux provides dividend imputation to Australian-resident shareholders from its Australian tax paid. Assume that Castor & Pollux pays a 85 % partly-franked dividend of $14.32 thousand to an Australian shareholder who currently has a taxable income of $250 thousand before dividends and a marginal tax rate of 32.5% and is NOT exempted from paying Medicare levy. Compute the franking credits this investor would receive from the partly-franked dividend received. O a. $4057.33 O b. $2148.00 c. $3109.83 d. $84197.24 e. $83779.87 O f. $2282.85 g. $1915.30

US Tax law contains a two-pronged system for taxing the US source income of foreign persons. Briefly explain this system.

How can a country’s tax system affect the manner in which an operation in that country is financed by a foreign investor?

1 canadian taxation-2 Which of the following scenarios would be most appropriate for a Section 85 rollover?     A shareholder of a corporation wishes to transfer property with a fair market value of $150,000 and a tax cost of $100,000 to his corporation.     A shareholder of a corporation wishes to transfer property with a fair market value of $100,000 and a tax cost of $150,000 to his corporation.     A shareholder of a corporation wishes to transfer property with a fair market value of $150,000 and a tax cost of $100,000 from his corporation.     A shareholder of a corporation wishes to transfer property with a fair market value of $100,000 and a tax cost of $150,000 from his corporation.

Reaction paper about the Legality of The Assault on Tax Avoidance Practices in the Philippines