USP, a domestic corporation, operates abroad through numerou…

USP, a domestic corporation, operates abroad through numerous foreign entities. In its first year of operations, USP reports the following results: USP operates in Country U through a 100%-owned foreign corporation that is a disregarded entity for U.S. tax purposes. This check-the-box branch reports $160,000 of taxable income and pays $25,000 of Country U corporate income taxes. USP’s 100%-owned Country V subsidiary reports $170,000 of taxable income, $34,000 of foreign income taxes, and current-year E&P of $136,000. All the E&P is Subpart F income. USP’s 100%-owned Country W subsidiary reports taxable income (non-Subpart F) of $180,000, pays $60,000 of foreign income taxes, and distributes a $120,000 dividend. Country W imposes a $7,000 withholding tax on the dividend. Thus, USP receives a payment of $113,000. What amount of net taxable income does USP report on line 30 of its Form 1120 because of these foreign entities?

USP, a domestic corporation, operates abroad through numerou…

USP, a domestic corporation, operates abroad through numerous foreign entities. In its first year of operations, USP reports the following results: USP operates in Country U through a 100%-owned foreign corporation that is a disregarded entity for U.S. tax purposes. This check-the-box branch reports $90,000 of taxable income and pays $25,000 of Country U corporate income taxes. USP’s 100%-owned Country V subsidiary reports $170,000 of taxable income, $34,000 of foreign income taxes, and current-year E&P of $136,000. All the E&P is Subpart F income. USP’s 100%-owned Country W subsidiary reports taxable income (non-Subpart F) of $180,000, pays $60,000 of foreign income taxes, and distributes a $120,000 dividend. Country W imposes a $7,000 withholding tax on the dividend. Thus, USP receives a payment of $113,000. What amount of net taxable income does USP report on line 30 of its Form 1120 because of these foreign entities?

USP, a domestic corporation, operates abroad through numerou…

USP, a domestic corporation, operates abroad through numerous foreign entities. In its first year of operations, USP reports the following results: USP operates in Country U through a 100%-owned foreign corporation that is a disregarded entity for U.S. tax purposes. This check-the-box branch reports $110,000 of taxable income and pays $25,000 of Country U corporate income taxes. USP’s 100%-owned Country V subsidiary reports $170,000 of taxable income, $34,000 of foreign income taxes, and current-year E&P of $136,000. All the E&P is Subpart F income. USP’s 100%-owned Country W subsidiary reports taxable income (non-Subpart F) of $180,000, pays $60,000 of foreign income taxes, and distributes a $120,000 dividend. Country W imposes a $7,000 withholding tax on the dividend. Thus, USP receives a payment of $113,000. What amount of net taxable income does USP report on line 30 of its Form 1120 because of these foreign entities?

USP is a domestic corporation. USP owns 100% of F, a foreign…

USP is a domestic corporation. USP owns 100% of F, a foreign corporation. During its first year of operations, F has $300,000 of pre-tax earnings and pays $42,000 in foreign income taxes. F’s $258,000 of E&P is attributable to $51,600 of Subpart F income and $206,400 of non-Subpart F income. What amount of US tax does USP owe by virtue of its ownership of F?