Accounting 482 Chapter 8

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For foreign operation located in highly inflationary countries, the U.S dollar must be used as the functional currency. Which countries would be considered as highly inflationary? a. countries with cumulative 3-year inflation exceeding 100% b. countries with uncontrollable inflation rates c. countries with increasing inflation rates in 3 years d. countries with annual inflation exceeding 10%

The average exchange rate for the year.

Jordan Inc., a U.S. company, is required to translate into U.S. dollars the foreign currency income generated by its foreign branch. To determine U.S. taxable income, what must Jordan use to translate the net income of its foreign branch into U.S. dollars?

The United States taxes its citizens on their worldwide income.

Kerry is a U.S. citizen residing in Portugal. Kerry receives some investment income from Spain. Why might Kerry be expected to pay taxes on the investment income to the United States?

Regarding to the basis of taxation, to determine jurisdictional authority countries usually use: 1. source of income 2. citizenship 3. residence a. Either 1 or 2 b. Only the combination of 1 and 3 c. 1, 2 or 3 or their combination d. Either 2 or 3

Regardless of the approach used in determining the scope of taxation, a second issue related to jurisdiction is: a. the basis of taxation b. the exchange rate to convert tax payment c. how tax payment is transferred across borders d. the currency of tax payment

The withholding tax rate on dividends in the U.S is 30%. Frucot, an U.S-based company, pays $200 dividend to a stockholder in Vietnam. What is the amount of tax withheld from the dividend payment? a. $70 b. $60 c. $30 d. $140

True or false: For tax purposes, gains and losses on forward contracts and options used to hedge foreign currency transactions and firm commitments are integrated with the underlying item being hedged. a. True b. False

True or false: The BEAT only applies to U.S corporations that are part of a group with average revenue of at least $500 million over the previous 3 years and have base erosion payments exceeding 3% of the company's total deductible expenses. a. True b. False

True or false: The U.S model treaty exempts interest and royalties from withholding tax. a. True b. False

True or false: The amount of CFC income currently taxable in the U.S depends on the percentage of CFC income generated from Subpart F activities. a. True b. False

True or false: To determine MNC's foreign tax credit, foreign taxes (both income tax and withholding tax) paid on the income taxable in the U.S must be determined. a. True b. False

True or false: Treaty shopping describes a process in which a resident of Country A uses a corporation in Country B to get the benefit of Country B's tax treaty with Country C. a. True b. False

Why would a country have tax holidays? a. To compete for foreign investment b. To protect domestic businesses c. To increase the amount of national holidays d. To raise more tax income for the government

Withholding taxes are imposed on payments made to foreign parent companies or foreign affiliated companies. The types of payments typically subject to withholding tax are all of the following, except: a. interest b. purchase on credit c. cash dividends d. royalties

A Vietnamese investor receives dividend payment from an investment in Amazon common stock. The problem of double taxation arises when: a. Both Vietnam and the US tax this dividend payment b. The US taxes this dividend payment because it was earned in the US c. Vietnam taxes the dividend payment because it was earned by a resident of Vietnam d. Singapore taxes this dividend payment because the payment was transferred using a Singaporean bank

A major type of taxes imposed on profits earned by companies engaged in international business is: a. state tax b. corporate income tax c. personal income tax d. federal tax

An important goal of most national tax systems is neutrality. In an international context, one of the standards for neutrality is: a. import-export neutrality b. balance payment c. capital-export neutrality d. balance trade

As part of the "Tax Cuts and Jobs Act" in the U.S, effective for tax years beginning 2018, what is the corporate income tax rate in the U.S? a. 21 percent b. 11 percent c. 35 percent d. 15 percent

Assume CNU Company's foreign branch earns income before income taxes of $200,000. Income taxes paid to the foreign government are computed based on a rate of 10%. Sales and other taxes paid to the foreign government are $10,000. CNU is a U.S company. The US income tax before credit is 21%. What is net U.S tax liability if CNU takes the tax credit? a. $32,000 b. $35,700 c. $22,000 d. $12,000

Assume CNU Company's foreign branch earns income before income taxes of $200,000. Income taxes paid to the foreign government are computed based on a rate of 10%. Sales and other taxes paid to the foreign government are $10,000. CNU is a U.S company. The US income tax before credit is 21%. What is net U.S tax liability if CNU takes the tax deduction? a. $37,800 b. $42,000 c. $35,700 d. $39,900

Assume CNU Company's foreign branch earns income before income taxes of $200,000. Income taxes paid to the foreign government are computed based on a rate of 10%. Sales and other taxes paid to the foreign government are $10,000. CNU is a U.S company. The US income tax before credit is 21%. What is the U.S taxable income if CNU takes the tax credit? a. $200,000 b. $170,000 c. $190,000 d. $180,000

Assume CNU Company's foreign branch earns income before income taxes of $200,000. Income taxes paid to the foreign government are computed based on a rate of 10%. Sales and other taxes paid to the foreign government are $10,000. CNU is a U.S company. The US income tax before credit is 21%. What is the U.S taxable income if CNU takes the tax deduction? a. $170,000 b. $180,000 c. $200,000 d. $190,000

Assume a citizen of Canada resides permanently in the U.S and earns dividends income from an investment in the shares of a Mexican company. Taxing on the basis of citizenship, in which country will this individual be subject to taxation? a. The U.S b. All three countries c. Canada d. Mexico

Assume a citizen of Italy resides permanently in France and earns dividends from an investment in the shares of a company in the U.S. Taxing on the basis of source of income, in which country will this individual be subject to taxation? a. France b. Italy c. The U.S d. European Union

Assume a citizen of Singapore resides permanently in the US and earns dividends from an investment in the shares of a company in UK. Taxing on the basis of residence, which country will this individual be subject to taxation? a. Singapore b. The UK c. The US d. China

Assume that Davis company (a U.S taxpayer) has a subsidiary located in Uzbekistan. The income tax rate in the U.S is 21%, in Uzbekistan is 7.5%, and the withholding tax rate in Uzbekistan is 10%. What is the effective tax rate of Uzbekistan? Is Uzbekistan a tax haven? a. 15%. No, it is not a tax haven b. 16.75%. Yes, it is a tax haven c. 16.75%. No, it is not a tax haven d. 15%. Yes, it is a tax haven

Assume that HKD company (a U.S taxpayer) has a subsidiary located in Zimbabwe. Income tax rate in the U.S is 21%, in Zimbabwe is 25%, withholding tax rate in Zimbabwe is 10%. What is the effective tax rate of Zimbabwe? Is Zimbabwe a tax haven? a. 32.5%. Yes, it is a tax haven b. 10%. No, it is not a tax haven c. 32.5%. No, it is not a tax haven d. 10%. Yes, it is a tax haven

Assuming that non of a CFC's income is repatriated as a dividend, which of the following is true: 1. If Subpart F income is less than 5 percent of the CFC's total income, then none of the CFC's income will be taxed currently 2. If Subpart F income is between 5 percent and 70 percent of the CFC's total income, then that percentage of the CFC's income which is Subpart F income will be taxed currently 3. If Subpart F income is greater than 70 percent of the CFC's total income, then 100 percent of the CFC's income will be taxed currently. a. 1, 2 and 3 b. 1 and 3 c. 1 and 2 d. 2 and 3

$42,000

Bush, Inc., has total worldwide income of $500,000. Bush's Polish branch has foreign source income of $200,000 and paid taxes of $38,000 to the Polish government. The U.S. corporate tax rate is 21 percent. What is Bush's overall foreign tax credit limitation?

Double taxation arises when: a. Two countries levy tax on the same income b. A country collects taxes on the same income in two years c. Countries double their tax rates d. Two countries levy tax on different incomes

Double taxation relief can be accomplished by: 1. To exempt some or all foreign source income from taxation by adopting a participation exemption or territorial approach to corporate income taxation 2. To allow the parent company to deduct the taxes paid to the foreign government in calculating its taxable income 3. To provide the parent company with a credit for taxes paid to the foreign government a. 1 and 2 b. 1 and 3 c. 1, 2 and 3 d. 2 and 3

Excess foreign tax credits (FTC) may be used to offset additional taxes paid to the U.S on foreign source income in years in which foreign tax rates are lower than the U.S tax rate. How many years can an excess FTC may be carried back? a. 5 years b. 10 years c. 2 years d. 1 year

How is the amount of taxes paid to a government determined? a. By only how taxable income is calculated b. By how expenses can be deducted for tax purposes c. By the corporate tax rate and the tax bracket of the taxable income d. By the corporate tax rate and the manner in which taxable income is calculated

How many years does the TCJA allow U.S corporations to pay their tax installments? a. 5 b. 2 c. 10 d. 8

If a Subpart F income of a controlled foreign corporation with a foreign effective tax rate less than 90% of U.S rate is less 5 percent, what will be the amount of foreign income taxable in the U.S? a. 15% of the Subpart F income b. The income is not taxable in the U.S c. 21% of the Subpart F income d. 100% of the Subpart F income

In 2013, the OECD developed an action plan to help nations close the gaps in tax laws that allows MNCs to artificially, but legally, reduce their taxes. The action plan covers issues such as: 1. designing effective controlled foreign corporation rules 2. limiting base erosion via interest deductions, mandatory disclosure of aggressive tax planning by MNCs 3. the design of domestic rules to prevent tax treaty abuse a. 2 and 3 b. 1 and 2 c. 1, 2 and 3 d. 1 and 3

In Malaysia, corporations that undertake a project involving the manufacture of specialized machinery and equipment receive: a. a 10 percent tax exemption for up to 10 years b. a 100 percent tax exemption for up to 10 years c. a 10 percent tax exemption for up to 20 years d. a 100 percent tax exemption for up to 20 years

In Sri Lanka, tax holidays ranging in length from ______ are provided, depending on the activity and size of investment. a. 1 to 10 years b. 1 to 100 years c. 4 to 100 years d. 4 to 12 years

In deciding whether to establish a foreign operation, which factor(s) might a multinational corporation (MNC) consider? a. After-tax returns from competing investment locations. b. The tax treatments of branches versus subsidiaries. c. Withholding rates on dividend and interest payments. d. All answers are correct.

In determining the net U.S tax liability on taxable foreign income, U.S companies are allowed to: 1. deduct all foreign taxes paid on the related foreign income 2. take a credit for foreign income taxes a. Only 1 b. Either 1 or 2 c. Both 1 and 2 d. Only 2

$8,250, $15,000, and $21,000.

Information for Year 1, Year 2, and Year 3 for the Alpinian branch of Rawl Corporation is presented in the following table. The corporate tax rate in the Alpinian Republic in Year 1 was 11 percent. In Year 2, the Alpinian Republic increased its corporate income tax rate to 15 percent. In Year 3, the Alpinian Republic increased its corporate tax rate to 22 percent. The U.S. corporate tax rate in each year is 21 percent. Year 1Year 2Year 3Foreign source income$75,000$100,000$100,000Foreign taxes paid 8,250 15,000 22,000U.S. tax before FTC 15,750 21,000 21,000 For Year 1, Year 2, and Year 3, what is the foreign tax credit allowed in the United States?

$0.

$1,000.

Information for Year 1, Year 2, and Year 3 for the Alpinian branch of Rawl Corporation is presented in the following table. The corporate tax rate in the Alpinian Republic in Year 1 was 11 percent. In Year 2, the Alpinian Republic increased its corporate income tax rate to 15 percent. In Year 3, the Alpinian Republic increased its corporate tax rate to 22 percent. The U.S. corporate tax rate in each year is 21 percent. Year 1Year 2Year 3Foreign source income$75,000$100,000$100,000Foreign taxes paid 8,250 15,000 22,000U.S. tax before FTC 15,750 21,000 21,000 In Year 3, how much excess foreign tax credit can Rawl carry back?

Interest, dividends, royalties, rents, and capital gains from sales of assets are considered as: a. service income b. Subpart E income c. passive income d. sales income

Multinational corporations make a number of very important decisions in which taxation is an important variable. Taxes issues are important in deciding all of the following, except: a. what legal form the operation should take b. where to locate a foreign operation c. which local culture to follow d. how the operation will be financed

On which of the following bases does the U.S levy tax on an income earned by a U.S individual in a foreign country? a. Types of income b. Residence basis and only for dual-citizenship individuals c. The U.S does not levy tax on foreign income d. Citizenship

One of the two approaches taken on foreign source income issue is: a. Territory approach b. Cultural approach c. Income source approach d. Single taxation approach

One of the two approaches taken on the issue of foreign source income is: a. Discretionary approach b. Double taxation approach c. Single taxation approach d. Worldwide approach

Double taxation.

Poole Corporation is a U.S. company with a branch in China. Income earned by the Chinese branch is taxed in both China, at the corporate income tax rate of 25 percent, and the United States, at the rate of 21 percent. What is this an example of?

The withholding tax rate for royalties recommended by the OECD model is: a. 0 percent b. 15 percent c. 5 percent d. 10 percent

Select the best answer to complete the following statement: "A controlled foreign corporation (CFC) is any foreign corporation in which U.S shareholders hold more than ______ percent of the combined voting power or fair market value of the stock. Only those U.S taxpayers directly or indirectly owning ______ percent more more of the stock are considered U.S shareholders in determining whether the threshold is met." a. 51, 15 b. 50, 10 c. 10, 51 d. 5, 10

Select the best answer to complete the following statement: "Almost all countries generally assert the jurisdictional authority to tax income where it is earned, also known as ______ regardless of the residence or citizenship of the recipient." a. source of income b. income tax bracket c. amounts of income d. types of income

Select the best answer to complete the following statement: "An important goal of most national tax systems is ______. The tax system should remain in the background, and business, investment and consumption decisions should be made for non-tax reasons." a. to increase tax collection b. neutrality c. to exempt foreign income taxes d. to provide tax credit

Select the best answer to complete the following statement: "Beginning 2018, a U.S parent company is entitled to a ______ dividends received deduction for dividends it receives from any 10-percent-or-greater-owned foreign operation." a. 100 percent b. 10 percent c. 50 percent d. 21 percent

Select the best answer to complete the following statement: "Beginning 2018, dividends received from foreign subsidiaries are ______ U.S corporate income taxation." a. subject to 21% of b. no longer subject to c. subject to 5%-10% of d. subject to 15% of

Select the best answer to complete the following statement: "Countries generally use ______ as a basis to determine jurisdictional authority." a. amounts of income b. source of income c. income tax bracket d. types of income

Select the best answer to complete the following statement: "Foreign operation net income is grossed up by ______ taxes paid to the foreign government translated at the exchange rate ______." a. deducting, at the date when the foreign operation was established b. adding, at the date of payment c. deducting, at the date of payment d. adding, at the date when the foreign operation was established

Select the best answer to complete the following statement: "In the U.S, the Foreign Tax Credit (FTC) allowed is equal to the ______ of (1) the actual taxes paid to the foreign government, or (2) the amount of taxes that would have been paid if the income had been earned in the U.S" a. lower b. higher c. difference d. total

Select the best answer to complete the following statement: "Several countries have a ______ rate of withholding tax on interest than on dividends. Interest payments are generally ______, whereas dividend payments ______. Thus, there is an incentive for companies to finance their foreign operations with as much debt and as little equity for possible." a. higher, tax deductible, are not b. higher, non-deductible, are deductible c. lower, non-deductible, are deductible d. lower, tax deductible, are not

Select the best answer to complete the following statement: "The BEAT - Based Erosion Anti-abuse Tax - is a new tax that is intended to apply to companies that significantly reduce their ______ by making payments to foreign affiliates (foreign parent, foreign subsidiary, or foreign branch)." a. foreign tax credit b. U.S tax credit c. U.S tax liability d. U.S tax asset

Select the best answer to complete the following statement: "The United Nations Model treaty, designed to be used ______, assumes ______." a. between developed and developing countries, an imbalance b. among developed countries, a balance c. between developed and well-developed countries, an imbalance d. among developing countries, a balance

Select the best answer to complete the following statement: "Under the ______ approach, residents of a country are taxed by the country in which they reside regardless of their citizenship or where the income was earned." a. citizenship b. income average c. residence d. source of income

Select the best answer to complete the following statement: "Under the safe harbor rule, if the foreign tax rate is greater than ______ percent of the U.S corporate income tax rate, then none of the CFC's income is considered to be Subpart F income." Multiple choice question. a. 50 b. 20 c. 10 d. 90

Select the best answer to complete the following statement: "______ are bilateral agreements between two countries regarding how companies and individuals from one country will be taxed when earning income in the other country." a. Investment treaties b. Tax treaties c. Income treaties d. Free-trade treaties

Select the best answer to complete the following statement: A tax system would be considered "capital-export neutral" if a taxpayer's decision whether to invest at home or overseas ______ by taxation. a. is not affected b. is affected c. is made d. is determined

Select the best answer to complete the following statement: To relieve the double taxation, the international norm is that ______ should take precedence over ______ in determining tax jurisdiction. a. residence, source b. residence, citizenship c. citizenship, source d. source, residence

The withholding tax rate for direct investment dividends (paid by a subsidiary to its parent) recommended by the OECD model is: a. 10 percent b. 0 percent c. 5 percent d. 15 percent

Tax issues are important in deciding: a. where to locate a foreign operations b. what legal form the operation should take c. how the operation will be financed a. a, b, and c b. only c c. only a d. only a and b

Tax planning by multinational entities to artificially shift profits to no- or low-tax jurisdictions (tax havens) where there is little or no real economic activity is referred to as: a. base erosion and profit shifting b. earnings management c. tax loss carry forward d. tax loss carry backward

The American Jobs Creation Act of 2004 required foreign source taxable income to be classified into two categories, also referred as "baskets". What are the two baskets? a. a sale income basket and a passive income basket b. a CPI basket and a GPI basket c. an income basket and a price index basket d. a general income basket and a passive income basket

The withholding tax rate for interest income recommended by the OECD model is: Multiple choice question. a. 15 percent b. 10 percent c. 5 percent d. 0 percent

The withholding tax rate for portfolio dividends (paid to individuals) recommended by the OECD model is: Multiple choice question. a. 15 percent b. 10 percent c. 0 percent d. 5 percent

The Tax Cuts and Jobs Act 2017 created an additional Foreign Tax Credit (FTC) basket for foreign branch income. What is/are the result(s) of this change? 1. Controlled Foreign Corporations (CFC) Subpart F income must be allocated to either a general income basket or a passive income basket 2. Foreign branch income must be allocated to a foreign branch income basket. 3. Companies are allowed to net FTCs across baskets. a. 1, 2 and 3 b. 1 and 3 c. 1 and 2 d. 2 and 3

The Tax Cuts and Jobs Act, passed in 2017, made the most extensive changes to the international tax provisions in U.S tax law since 1986. Besides the adoption of a participation exemption system of taxation in which most foreign subsidiary income is exempt from U.S taxation. Other major international tax provisions of the new law are all of the followings, except: a. A full adoption of OECD model b. Deemed repatriation of accumulated foreign earnings c. Taxation of global intangible low-taxed income d. Imposition of a base erosion anti-abuse tax

The amount of taxes that would have been paid if the income had been earned in the U.S can be computed by: a. dividing the amount of foreign source of taxable income by the total taxable income of the parent company b. multiplying the amount of foreign source taxable income by 15 percent c. multiplying the amount of foreign source taxable income by the effective U.S corporate income tax rate d. multiplying the amount of foreign source taxable income by 21 percent

The appropriate translation procedures for determining U.S taxable income depend on: a. the local currency of the foreign operation b. the functional currency of the foreign operation c. the reporting currency of the parent d. the functional currency of the parent

The factors used to determine the appropriate amount of U.S taxable income from foreign operations are all of the following, except: a. Nature of the foreign source income b. Effective foreign tax rate c. Percentage level of ownership d. Current U.S corporate tax rate e. Legal form of the foreign operation

The factors used to determine the appropriate amount of U.S taxable income from foreign operations are: 1. Legal form of the foreign operation (branch or corporation) 2. Percentage level of ownership (controlled foreign corporation or not) 3. Effective foreign tax rate ("tax haven" or not) 4. Nature of the foreign source income (Subpart F income or not) (appropriate foreign tax credit basket) a. 3 and 4 b. 2, 3 and 4 c. 1, 2, 3 and 4 d. 1, 2 and 3

(Foreign Source Taxable Income / Worldwide Taxable Income) *US Taxes before FTC

The overall Foreign Tax Credit (FTC) limitation is calculated as follows:

The tax jurisdictions with abnormally low corporate income tax rates or no corporate income tax at all are known as: a. Tax holiday b. Tax havens c. Tax exemption d. Tax reduction

The types of Subpart F income are: 1. Income derived from insurance of U.S risks 2. Income from countries engaged in international boycotts 3. Certain illegal payments 4. Foreign base company income a. 1, 2 and 4 b. 2, 3 and 4 c. 1, 2, 3 and 4 d. Only 3

Under the TCJA, at which tax rate were the deemed repatriated earnings held in cash or cash equivalents taxed? a. 8% b. 21% c. 15.5% d. 35%

Under the TCJA, at which tax rate were the deemed repatriated earnings that had been invested in noncash assets taxed? a. 8% b. 35% c. 15.5% d. 21%

Under the United Nations Model, which host countries should have more taxing rights when profit repatriation essentially is a one-way street? a. All countries b. developed countries c. developing countries d. North American countries

Under the safe harbor rule, if the foreign tax rate is greater than 90 percent of the U.S corporate income tax rate, then none of the CFC's income is considered to be Subpart F income. With the current U.S tax rate of 21 percent, U.S MNCs need not be concerned with the CFC rules for those foreign operations located in countries with an effective tax rate of: a. 18.9 percent or lower b. 18.9 percent or higher c. 21 percent or lower d. 21 percent or higher

VinGroup is a controlled foreign corporation located in a foreign country with an effective tax rate greater than 90% of U.S rate, what will be the amount of foreign income taxable in the U.S? a. 21% of the Subpart F income b. 15% of the Subpart F income c. 100% of the Subpart F income d. The foreign income is not taxable in the U.S

Exempting some foreign source income, allowing a deduction for all foreign taxes paid, and providing a foreign tax credit for foreign income taxes paid.

What are the methods used by the United States to reduce the double taxation of income earned by foreign operations of U.S. companies?

What does "global intangible low-taxed income" refer to? a. the income earned by controlled foreign corporations (CFC) exceeding a specified return on all CFCs' intangible assets b. the income earned by controlled foreign corporations (CFC) below a specified return on all CFCs' intangible assets c. the income earned by controlled foreign corporations (CFC) below a specified return on all CFCs' tangible assets d. the income earned by controlled foreign corporations (CFC) exceeding a specified return on all CFCs' tangible assets

What is a functional currency? a. the currency in which the foreign operation primarily conducts business b. a currency rather than the local currency, or the reporting currency c. the local currency of the foreign operation d. the parent reporting currency

What is the range of the value-added tax in the European Union? a. 17% to 27% b. 30% to 35% c. 0% to 5% d. 5% to 10%

What type of tax is usually levied on the value added at each stage in the production or distribution of a product or service? a. Value withholding tax b. Production tax c. Sales tax d. Value-added tax

Which country in 2017 had the highest effective corporate income tax rate? a. Malaysia b. The U.S c. Canada d. Spain

Which exchange rate is used to translate foreign operation net income taxable in the U.S? a. the average exchange rate for the year b. the historical exchange rate when the foreign operation was established c. the current exchange rate d. the average exchange rate for the past 3 years

Which of the following items might provide an MNC with a tax-planning opportunity as it decides where to locate a foreign operation? a. Differences in corporate tax rates across countries. b. Differences in local tax rates across countries. c. Whether a country offers a tax holiday. d. All answers are correct.

Tax havens are jurisdictions that tend to have abnormally low corporate income tax rates.

Why might a company involved in international business find it beneficial to establish an operation in a tax haven?

Interest payments are generally tax deductible and withholding rates are lower for interests.

Why might companies have an incentive to finance their foreign operations with as much debt as possible?

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