Wood, a U.S. corporation, owns 30% of Hout, a foreign corporation. The remaining 70% of Hout is owned by other foreign corporations not controlled by Wood. Hout's functional currency is the euro. Wood receives a 50,000€ distribution from Hout. If the average exchange rate for the E & P to which the dividend is attributed is 1.2€: $1, the exchange rate at year end is .95€: $1, and on the date of the dividend payment the exchange rate is 1.1€: $1, what is Wood's tax result from the distribution?
A) Wood receives a dividend of $45,455 and realizes an exchange gain of $3,788 [$45,455 minus $41,667 (50,000€/1.2) ].
B) Wood receives a dividend of $52,632 (50,000€/.95) with no exchange gain or loss.
C) Wood receives a dividend of $41,667 and realizes an exchange loss of $3,788 ($41,667 minus $45,455) .
D) Wood receives a dividend of $45,455 (50,000€/1.1) with no exchange gain or loss.
Correct Answer:
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