Deck 9: International Tax Services

Question 1

The International Bureau of Fiscal Documentation IBFD) is:

A) an independent agency which provides authoritative expertise to tax practitioners around the globe with regard to cross-border taxation.
B) an association of countries that monitors world economics.
C) a website with links to numerous international tax web pages.
D) none of the above.

Answer 1

A

Question 2

The RIA tax product which provides a comprehensive set of analytical treaties and texts is named:

A) RIA International Taxes Weekly
B) Tax Management Portfolios.
C) RIA International Tax Library ITL)
D) Worldwide Tax Treaties.

Answer 2

C

Question 3

Which of the following statements is CORRECT regarding the U.S. foreign tax credit?

A) The credit is unlimited and is allowed for the full amount of foreign taxes.
B) The credit is limited to the amount of U.S. taxes that would be due on the income.
C) The credit is only allowed for taxes paid in countries which have a tax treaty with the U.S.
D) None of the above statements is correct.

Answer 3

B

Question 4

BNA's Premier International Tax Library includes:

A) an international create-a-chart feature.
B) CCH's Tax Treaties Reporter.
C) Tax Notes International.
D) Tax Management Portfolios

Question 5

The difference between the net earnings that a worker takes home at the end of the year and what it costs to employ that worker tracked by the OECD) is called:

A) average wages after taxes.
B) the tax wedge.
C) U.S. source income.
D) none of the above.

Question 6

Expenses that are either not attributable to any specific income source or are associated with more than one source are known as:

A) U.S. source deductions.
B) apportioned deductions.
C) 'not definitely related' deductions.
D) none of the above.

Question 7

Most countries require a transfer pricing scheme that adheres to:

A) a territorial model.
B) safe harbor methods.
C) an arm's length principle.
D) all of the above.

Question 8

Tax treaties can prevent double taxation by:

A) providing reduced tax rates and reduced withholding.
B) exempting certain types of income from taxation.
C) including a "savings clause."
D) all of the above.
E) only a) and b).

Question 9

English translations of tax and commercial law for approximately 90 countries are offered through which service?

A) Worldwide Tax Treaties by Tax Analysts.
B) RIA Tax Advisors Planning System.
C) RIA's Worldwide Tax Law WTL).
D) CCH's Global Transaction Library.

Question 10

A model under which a country imposes taxes on residents based on their worldwide income, regardless of its source, is called a:

A) pure transaction model
B) foreign credit model
C) territorial model
D) none of the above.

Question 11

Under its blended model, the U.S. taxes corporate income in the following way:

A) It imposes taxes on the worldwide income of domestic corporations and the income of foreign entities that is connected with a U.S. business.
B) It imposes taxes on worldwide income of domestic corporations even if the income is not brought back into the U.S.
C) It gives an unlimited foreign tax credit for the full amount of taxes paid to other countries.
D) All of the above.

Question 12

The International Tax Journal is published by:

A) Tax Analysts.
B) Westlaw.
C) CCH.
D) The OECD.

Question 13

Which of the following statements describes the international tax services offered by LexisNexis?

A) LexisNexis contains a Westlaw International Tab.
B) Only primary sources are available.
C) LexisNexis contains international publications by BNA, CCH, Wiley, and Tax Analysts.
D) All of the above statements accurately describe LexisNexis international tax services.

Question 14

A model under which a country imposes taxes only on incomes earned within its own border is called a:

A) foreign income model.
B) worldwide model.
C) territorial model
D) blended model
E) none of the above.

Question 15

The source determination of income is dependent on:

A) the amount of the taxpayer's taxable income.
B) the taxpayer's business or profession
C) performance location and/ or property location.
D) all of the above.

Question 16

A country where the taxpayer is a citizen or a legal resident is called the:

A) transaction country
B) native country
C) reporting country
D) worldwide country

Question 17

Which statement is INCORRECT regarding the sourcing of deductions in U.S. international taxation?

A) Deductions and losses must be apportioned between domestic and foreign-source gross income.
B) Definitely related deductions associated with more than one source must be apportioned.
C) Definitely related deductions are relatively simple to allocate.
D) All of the above statements are correct.

Question 18

The OECD is an organization known for its:

A) belief in democratic governments and market economies.
B) support of tax havens.
C) publication of economic and social data and statistics.
D) only a) and c).

Question 19

Tax Notes International is published by:

A) Westlaw
B) Tax Analysts
C) CCH
D) RIA

Question 20

CCH International taxation materials include the:

A) Worldwide Tax Daily newsletter created in conjunction with Tax Analysts.
B) International Tax Planning Library.
C) Global Tax Center developed by LexisNexis
D) Foreign Income Library of the Tax Management Portfolios.
E) all of the above.

Question 21

Generally, inventory sales are sourced by the location of the seller.

Question 22

U.S. tax law uses a territorial approach for taxing non-U.S. taxpayers.

Question 23

Originally, the IBFD was simply a document repository, but now it provides expert research products.

Question 24

"Savings clauses" in U.S. treaties prevent U.S. residents from using treaty provisions to avoid taxes on U.S. source income.

Question 25

The transfer pricing rules target multinational companies that use the price-setting process in intercompany transactions to report low taxable income in high-tax countries and high taxable income in the low-tax countries.

Question 26

Westlaw offers one portal to international taxation materials, through the standard service, Westlaw Taxation.

Question 27

In practice, most of the countries in the world use a pure worldwide model of taxation.

Question 28

Tax Notes International is a daily publication.

Question 29

The ultimate goal of a corporate tax director in international tax planning is to reduce the company's overall global effective tax rate.

Question 30

A native country's taxation of its citizens' foreign-source income involves inbound transactions.

Question 31

Westlaw offers the business primers, "Doing Business in…" for a variety of countries that provide an overview of different countries' tax environments.

Question 32

The Create-a-Chart, a special feature of RIA Checkpoint, develops personalized charts of pertinent information for countries selected by the practitioner.

Question 33

BNA offers Country Portfolios covering the taxation of business operations in specific countries.

Question 34

The U.S. blended model encourages U.S. domestic corporations to retain earnings in foreign countries and postpone repatriation as long as possible.

Question 35

CCH offers the International Tax Planning Library.

Question 36

U.S.-adopted tax treaties usually do not address state and local tax issues.

Question 37

With a territorial model of taxation, a foreign tax credit is needed to ensure that the income is not taxed twice.

Question 38

The newsletter, International Taxes Weekly, is published by Westlaw.

Question 39

Worldwide Tax Rates and Answers, a service of CCH, provides corporate tax rates by country, including national and local tax rates, as well as current forms and instructions for countries around the world.

Question 40

A transaction country is a country where the taxpayer resides or an entity is located.

Question 41

Briefly explain the U.S. blended model of international taxation and the purpose of the foreign tax credit.

Question 42

"The Code provisions always take precedence over treaty provisions." Comment.
Essay Questions

Question 43

How is the source of income determined for the purpose of taxation? Briefly identify the sourcing rules for the following types of income: dividends, services, sales of inventory and income from property.

Question 44

Discuss in brief about some of the most useful resources offered within the CCH International Tax Service.

Question 45

Discuss the variety of international products offered by RIA.

Question 46

Distinguish between 'definitely related deductions' and 'not definitely related' deductions.