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(SOLVED) Drake Inc a U S corporation operates a branch

sales office
Drake, Inc., a U.S. corporation, operates a branch sales office in Turkey. During the current
year, Drake earned $500,000 in taxable income from U.S. sources and $100,000 in taxable
income from sources in Turkey. Drake paid $40,000 in income taxes to Turkey. All of the
income is characterized as general […]

Fleming, Inc., a domestic corporation, operates in both Canada and the United States. This
year, the business generated taxable income of $400,000 from foreign sources and $300,000
from U.S. sources. All of Fleming’s foreign-source income is in the general limitation basket.
Fleming’s total worldwide taxable income is $700,000. Fleming pays […]

ABC, Inc., a domestic corporation, owns 100% of HighTax, a foreign corporation. HighTax has
$50 million of undistributed E & P, all of which is attributable to general limitation income, and
$30 million of foreign income taxes paid. HighTax distributes a $5 million dividend to ABC. The
dividend, which is […]

Mary, a U.S. citizen, is the sole shareholder of CanCo, a Canadian corporation. During its first
year of operations, CanCo earns $14 million of foreign-source taxable income, pays $6 million
of Canadian income taxes, and distributes a $2 million dividend to Mary. Can Mary claim a
deemed-paid (indirect) foreign tax […]

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Mary is a shareholder in Sheets, Inc., a calendar year S corporation. At the beginning of the
year, her stock basis is $10,000, her share of the AAA is $2,000, and her share of corporate
AEP is $6,000. At the end of the year, Mary receives a $6,000 cash distribution […]

C&C Properties is an S corporation that owns two rental real estate undertakings: Carrot Plaza
and Cantaloupe Place. Both properties produce an annual $10,000 operating loss. C&C’s
Schedule K aggregates the results of the two locations into one number. Dan and Marta, C&C’s
two equal shareholders, both hold a $7,000 […]

One of your clients, Texas, Inc., is considering electing S status. Both of Texas’s equal
shareholders paid $30,000 for their stock. As of the beginning of 2013, Texas’s Subchapter C
NOL carryforward is $110,000. Its taxable income projections for the next few years are as
follows. Will you counsel Texas […]

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