Question 1

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Foreign base company income
b.Foreign personal holding company income
c.Controlled foreign corporation
d.U.S. shareholder
e.Previously taxed income
f.More than 10 percent
g.More than 50 percent
h.More than 80 percent
-A CFC's profits from sales of goods and services.

Accepted Answer

Foreign base company income refers to income earned by a Controlled Foreign Corporation (CFC) from certain types of passive income or income from sales and services that do not meet specific requirements related to economic connection with the CFC's country of incorporation.

Question 2

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-Foreign tax credit allowed when a foreign corporation makes a distribution to its parent corporation.

Accepted Answer

The answer of Match the definition with the correct term....

Question 3

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-Number of foreign tax credit limitation baskets.

Accepted Answer

The answer of Match the definition with the correct term....

Question 4

Match the definition with the correct term.
a.Inbound
b.Outbound
c.Allocation and apportionment
d.Qualified business unit
e.Tax haven
f.Income tax treaty
g.Section 482
-Method for sourcing income and deductions.

Accepted Answer

The answer of Match the definition with the correct term.
a.Inbound
b.Outbound
c.Allocation...

Question 5

Match the definition with the correct term.
a.Expatriate
b.Resident
c.Nonresident alien
d.U.S. trade or business
e.Branch profits tax
f.Effectively connected income
-Individual who is not a U.S.citizen or resident.

Accepted Answer

A nonresident alien is the correct term for an individual who is not a U.S. citizen or resident. This term is used in tax contexts to refer to individuals who have not passed the green card test or the substantial presence test, and thus are not considered residents for tax purposes.

Question 6

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-A deemed paid foreign tax credit is included in gross income.

Accepted Answer

The answer of Match the definition with the correct term....

Question 7

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-Ownership percentage required before a deemed paid foreign tax credit is allowed.

Accepted Answer

The answer of Match the definition with the correct term....

Question 8

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-A net loss in all foreign tax credit limitation baskets.

Accepted Answer

The answer of Match the definition with the correct term....

Question 9

Match the definition with the correct term.
a.Inbound
b.Outbound
c.Allocation and apportionment
d.Qualified business unit
e.Tax haven
f.Income tax treaty
g.Section 482
-Treasury powers over transfer pricing.

Accepted Answer

Section 482 of the Internal Revenue Code grants the U.S. Treasury the authority to adjust income, deductions, credits, or allowances between related entities to prevent evasion of taxes or to clearly reflect income. This is directly related to transfer pricing, which involves the pricing of goods, services, and intangible property between related entities.

Question 10

Match the definition with the correct term.
a.Inbound
b.Outbound
c.Allocation and apportionment
d.Qualified business unit
e.Tax haven
f.Income tax treaty
g.Section 482
-A country with very low or no income tax.

Accepted Answer

A tax haven is a country or jurisdiction with very low or no income tax rates, making it attractive for individuals and businesses seeking to reduce their tax liabilities.

Question 11

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Foreign base company income
b.Foreign personal holding company income
c.Controlled foreign corporation
d.U.S. shareholder
e.Previously taxed income
f.More than 10 percent
g.More than 50 percent
h.More than 80 percent
-Owner of shares counted in determining whether a foreign corporation is a controlled foreign corporation.

Accepted Answer

A U.S. shareholder is defined as a U.S. person who owns, directly or indirectly, 10% or more of the total combined voting power of all classes of stock of a foreign corporation. This definition is crucial in determining whether a foreign corporation is a controlled foreign corporation (CFC), as the ownership percentage of U.S. shareholders is a key factor.

Question 12

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Foreign base company income
b.Foreign personal holding company income
c.Controlled foreign corporation
d.U.S. shareholder
e.Previously taxed income
f.More than 10 percent
g.More than 50 percent
h.More than 80 percent
-Upon repatriation to a CFC,it does not create dividend income.

Accepted Answer

Previously taxed income (PTI) refers to earnings of a Controlled Foreign Corporation (CFC) that have already been taxed to the U.S. shareholder under the Subpart F or Global Intangible Low-Taxed Income (GILTI) provisions. Upon repatriation, these earnings do not create dividend income because they have already been included in the gross income of the U.S. shareholder.

Question 13

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-Maximum years for a foreign tax credit carryback.

Accepted Answer

The answer of Match the definition with the correct term....

Question 14

Match the definition with the correct term.
a.Expatriate
b.Resident
c.Nonresident alien
d.U.S. trade or business
e.Branch profits tax
f.Effectively connected income
-Activity that creates the potential for effectively connected income.

Accepted Answer

U.S. trade or business activity creates the potential for income to be considered effectively connected income, which is significant for tax purposes for nonresident aliens and foreign corporations engaged in trade or business within the U.S.

Question 15

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-Foreign tax credit allowed for withholding taxes on payments from foreign sources.

Accepted Answer

The answer of Match the definition with the correct term....

Question 16

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Foreign base company income
b.Foreign personal holding company income
c.Controlled foreign corporation
d.U.S. shareholder
e.Previously taxed income
f.More than 10 percent
g.More than 50 percent
h.More than 80 percent
-Ownership threshold for U.S.shareholders to be deemed a controlled foreign corporation.

Accepted Answer

The answer of Match the definition with the correct term....

Question 17

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Foreign base company income
b.Foreign personal holding company income
c.Controlled foreign corporation
d.U.S. shareholder
e.Previously taxed income
f.More than 10 percent
g.More than 50 percent
h.More than 80 percent
-Portfolio income treated as Subpart F income.

Accepted Answer

The answer of Match the definition with the correct term....

Question 18

Match the definition with the correct term.
a.Inbound
b.Outbound
c.Allocation and apportionment
d.Qualified business unit
e.Tax haven
f.Income tax treaty
g.Section 482
-A business operation that accounts for profits and losses using its functional currency.

Accepted Answer

A Qualified Business Unit (QBU) is a separate and clearly identified unit of a trade or business that maintains separate books and records. It is relevant in accounting for profits and losses in the functional currency, which is the currency of the primary economic environment in which the business operates.

Question 19

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Foreign base company income
b.Foreign personal holding company income
c.Controlled foreign corporation
d.U.S. shareholder
e.Previously taxed income
f.More than 10 percent
g.More than 50 percent
h.More than 80 percent
-A non-U.S.subsidiary whose income may be taxed to the U.S.parent before repatriation.

Accepted Answer

Controlled foreign corporations (CFCs) are non-U.S. companies controlled by U.S. shareholders, and their income can be taxed to the U.S. parent before it is actually repatriated. This is to prevent U.S. entities from deferring U.S. tax by holding profits in foreign subsidiaries.

Question 20

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once.
a.Indirect credit
b.Direct credit
c.One
d.Two
e.Ten
f.Twenty
g.Gross-up (§ 78)
h.​Overall foreign loss
-Maximum years for a foreign tax credit carryforward.

Accepted Answer

The answer of Match the definition with the correct term....

Quiz 25: Taxation of International Transactions

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -Number of foreign tax credit limitation baskets.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -Method for sourcing income and deductions.

Match the definition with the correct term. a.Expatriate b.Resident c.Nonresident alien d.U.S. trade or business e.Branch profits tax f.Effectively connected income -Individual who is not a U.S.citizen or resident.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -A deemed paid foreign tax credit is included in gross income.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -A net loss in all foreign tax credit limitation baskets.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -Treasury powers over transfer pricing.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -A country with very low or no income tax.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -Maximum years for a foreign tax credit carryback.

Match the definition with the correct term. a.Expatriate b.Resident c.Nonresident alien d.U.S. trade or business e.Branch profits tax f.Effectively connected income -Activity that creates the potential for effectively connected income.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -A business operation that accounts for profits and losses using its functional currency.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -Maximum years for a foreign tax credit carryforward.

Quiz 25: Taxation of International Transactions

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.​Overall foreign loss -Number of foreign tax credit limitation baskets.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -Method for sourcing income and deductions.

Match the definition with the correct term. a.Expatriate b.Resident c.Nonresident alien d.U.S. trade or business e.Branch profits tax f.Effectively connected income -Individual who is not a U.S.citizen or resident.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.​Overall foreign loss -A deemed paid foreign tax credit is included in gross income.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.​Overall foreign loss -A net loss in all foreign tax credit limitation baskets.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -Treasury powers over transfer pricing.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -A country with very low or no income tax.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.​Overall foreign loss -Maximum years for a foreign tax credit carryback.

Match the definition with the correct term. a.Expatriate b.Resident c.Nonresident alien d.U.S. trade or business e.Branch profits tax f.Effectively connected income -Activity that creates the potential for effectively connected income.

Match the definition with the correct term. a.Inbound b.Outbound c.Allocation and apportionment d.Qualified business unit e.Tax haven f.Income tax treaty g.Section 482 -A business operation that accounts for profits and losses using its functional currency.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.​Overall foreign loss -Maximum years for a foreign tax credit carryforward.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -Number of foreign tax credit limitation baskets.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -A deemed paid foreign tax credit is included in gross income.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -A net loss in all foreign tax credit limitation baskets.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -Maximum years for a foreign tax credit carryback.

Match the definition with the correct term. Not all of the terms have a match. A definition can be used more than once. a.Indirect credit b.Direct credit c.One d.Two e.Ten f.Twenty g.Gross-up (§ 78) h.Overall foreign loss -Maximum years for a foreign tax credit carryforward.