Deck 21: Multinational Tax Management
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Deck 21: Multinational Tax Management
1
The primary objective of multinational tax planning is to minimize the firm's worldwide tax burden.
True
2
A ________ tax policy is one that has no impact on private decision-making, while a ________ policy is designed to encourage specific behavior.
A) flat; tax incentive
B) neutral; flat
C) neutral; tax incentive
D) none of the above
A) flat; tax incentive
B) neutral; flat
C) neutral; tax incentive
D) none of the above
neutral; tax incentive
3
What is the total value of taxes paid in the following example if the value added tax is 10%? A farmer raises wheat that he sells for $1.50 to the grain company. The grain company sells to the processor for $2.00 per bushel. The processor turns the wheat into a breakfast cereal and wholesales it for $3.00 per bushel. The retailer sells the cereal for $4.00 per bushel.
A) $0.15
B) $0.20
C) $0.30
D) $0.40
A) $0.15
B) $0.20
C) $0.30
D) $0.40
$0.40
4
The territorial approach to taxation policy is also termed the ________ approach.
A) source
B) ethical
C) greedy
D) location
A) source
B) ethical
C) greedy
D) location
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5
Which of the following is NOT an example of a tax incentive policy.
A) The federal government gives a tax credit to MNEs that make domestic capital improvements but not foreign capital improvements.
B) Corporations are allowed to take a direct tax credit for each dollar of matching donations they make to institutions of higher education.
C) A tax law is passed that makes interest on property non tax-deductible, but interest payments on durable goods are.
D) All are examples of a tax incentive policy.
A) The federal government gives a tax credit to MNEs that make domestic capital improvements but not foreign capital improvements.
B) Corporations are allowed to take a direct tax credit for each dollar of matching donations they make to institutions of higher education.
C) A tax law is passed that makes interest on property non tax-deductible, but interest payments on durable goods are.
D) All are examples of a tax incentive policy.
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6
Tax treaties generally have the effect of increasing the withholding taxes between the countries that are negotiating the treaties.
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7
A tax that is effectively a sales tax at each stage of production is defined as a/an ________ tax.
A) flat
B) equitable
C) value-added tax
D) none of the above
A) flat
B) equitable
C) value-added tax
D) none of the above
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8
The basic idea behind withholding taxes for foreign investors is
A) to receive taxes on passively earned income.
B) a recognition that most foreign investors are unlikely to file taxes in the host country.
C) to ensure that income earned is taxed by the host country.
D) all of the above.
A) to receive taxes on passively earned income.
B) a recognition that most foreign investors are unlikely to file taxes in the host country.
C) to ensure that income earned is taxed by the host country.
D) all of the above.
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9
The United States taxes the domestic and remitted foreign earnings of U.S. based MNEs no matter where the earnings occurred. This is an example of a ________ approach to levying taxes.
A) worldwide
B) territorial
C) neutral
D) equitable
A) worldwide
B) territorial
C) neutral
D) equitable
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10
A value-added tax has gained widespread usage in Western Europe, Canada, and parts of Latin America.
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11
A ________ is a direct reduction of taxes whereas a ________ reduces the taxable income before taxes.
A) foreign tax credit; domestic tax credit
B) tax deduction; tax credit
C) tax credit; tax deduction
D) none of the above
A) foreign tax credit; domestic tax credit
B) tax deduction; tax credit
C) tax credit; tax deduction
D) none of the above
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12
The United States taxes all earnings on U.S. soil by both domestic and foreign firms. This is an example of a ________ approach to levying taxes.
A) worldwide
B) neutral
C) territorial
D) none of the above
A) worldwide
B) neutral
C) territorial
D) none of the above
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13
Jensen Optimetrics Inc. is based in a country with a territorial approach to taxation but generates 100% of its income in a country with a worldwide approach to taxation. The tax rate in the country of incorporation is 25%, and the tax rate in the country where they earn their income is 50%. In theory, and barring any special provisions in the tax codes of either country, Jensen should pay taxes at a rate of ________.
A) 75%
B) 62.5%
C) 0%
D) 50%
A) 75%
B) 62.5%
C) 0%
D) 50%
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14
A tax that is a form of social redistribution of income is defined as a/an ________ tax.
A) un-American
B) transfer
C) flat
D) none of the above
A) un-American
B) transfer
C) flat
D) none of the above
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15
General Motors operates in many different countries and pays taxes at many different rates. However, they always pay the same rate as their local competitors. General Motors is operating in an environment of ________ tax policy.
A) domestic neutrality
B) foreign neutrality
C) territorial approach
D) none of the above
A) domestic neutrality
B) foreign neutrality
C) territorial approach
D) none of the above
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16
Depending on the host country, corporate income taxes worldwide may be as low as ________.
A) 0%
B) 5%
C) 10%
D) 15%
A) 0%
B) 5%
C) 10%
D) 15%
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17
Which of the following is an unlikely objective of U.S. government policy for the taxation of foreign MNEs?
A) to raise revenues
B) to provide an incentive for U.S. private investment in developing countries
C) to improve the U.S. balance of payments
D) All of the above are objectives.
A) to raise revenues
B) to provide an incentive for U.S. private investment in developing countries
C) to improve the U.S. balance of payments
D) All of the above are objectives.
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18
________ taxes are applied to income and ________ taxes are applied to some other measurable performance characteristic of the firm.
A) Income; direct
B) Indirect; income
C) Indirect; direct
D) Direct; indirect
A) Income; direct
B) Indirect; income
C) Indirect; direct
D) Direct; indirect
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19
A country CANNOT have both a territorial and a worldwide approach as a national tax policy.
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20
The issue of ethics in the reporting of income and the payment of taxes is a considerable one. The authors state that most MNEs operating in foreign countries tend to follow the general principle of
A) "when in Rome, do as the Romans do."
B) full disclosure to the tax authorities.
C) maintain a competitive playing field by cheating as much as the local competition, no more, no less.
D) none of the above.
A) "when in Rome, do as the Romans do."
B) full disclosure to the tax authorities.
C) maintain a competitive playing field by cheating as much as the local competition, no more, no less.
D) none of the above.
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21
Poland has a corporate income tax rate that is higher than that in the United States by the amount of 40% in Poland and 35% in the U.S. This differential mean that a U.S. parent operating with a subsidiary in Poland can realize an
A) excess profit on their Polish investment.
B) excess foreign tax deficit.
C) excess foreign tax credit.
D) none of the above.
A) excess profit on their Polish investment.
B) excess foreign tax deficit.
C) excess foreign tax credit.
D) none of the above.
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22
TABLE 21.1
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. If MetroCity pays out 50% of its earnings from each subsidiary, what are the additional U.S. taxes due on the foreign sourced income from the Ukraine and Korea respectively.
A) Ukraine = $0; Korea = ($30,000)
B) Ukraine = $100,000; Korea = $0
C) Ukriane$0; Korea = $66,250
D) None of the above
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. If MetroCity pays out 50% of its earnings from each subsidiary, what are the additional U.S. taxes due on the foreign sourced income from the Ukraine and Korea respectively.
A) Ukraine = $0; Korea = ($30,000)
B) Ukraine = $100,000; Korea = $0
C) Ukriane$0; Korea = $66,250
D) None of the above
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23
TABLE 21.1
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. The additional U.S. taxes due on the repatriation of income from the Ukraine to the United States, alone, assuming a 50% payout rate, is
A) excess foreign tax credits of $110,000.
B) additional U.S. taxes due of $97,000.
C) additional U.S. taxes due of $36,500.
D) excess foreign tax credits of $18,500.
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. The additional U.S. taxes due on the repatriation of income from the Ukraine to the United States, alone, assuming a 50% payout rate, is
A) excess foreign tax credits of $110,000.
B) additional U.S. taxes due of $97,000.
C) additional U.S. taxes due of $36,500.
D) excess foreign tax credits of $18,500.
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24
Domestic tax neutrality means that
A) a dollar earned anywhere in the world by a U.S. corporation is taxed the same as if earned in the U.S.
B) tax rates are neither regressive nor progressive.
C) foreign affiliates must neutralize their income by subtraction of foreign investment credits.
D) all of the above.
A) a dollar earned anywhere in the world by a U.S. corporation is taxed the same as if earned in the U.S.
B) tax rates are neither regressive nor progressive.
C) foreign affiliates must neutralize their income by subtraction of foreign investment credits.
D) all of the above.
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25
Which of the following is NOT a disadvantage of the value-added tax?
A) The tax may have an inflationary impact.
B) It is a regressive tax.
C) It increases the total tax burden.
D) All are disadvantages.
A) The tax may have an inflationary impact.
B) It is a regressive tax.
C) It increases the total tax burden.
D) All are disadvantages.
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26
TABLE 21.1
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. What is the minimum effective tax rate that MetroCity can achieve on its foreign-sourced income?
A) 26%
B) 35%
C) 40%
D) 0%
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. What is the minimum effective tax rate that MetroCity can achieve on its foreign-sourced income?
A) 26%
B) 35%
C) 40%
D) 0%
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27
Tax credits are less valuable on a dollar-for-dollar basis than are tax-deductible expenses.
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28
Developing foreign markets can create shareholder value. Manipulating global tax payments does not create shareholder value.
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29
The value-added tax is
A) similar to an ad valorem tax on imports.
B) a form of direct taxation on corporate income.
C) a form of national sales tax.
D) none of the above.
A) similar to an ad valorem tax on imports.
B) a form of direct taxation on corporate income.
C) a form of national sales tax.
D) none of the above.
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30
Which of the following factors is not important for U.S. corporations for determining the amount of foreign tax credit allowed for direct taxes paid on income in a foreign country?
A) the Foreign corporate income tax rate
B) the U.S. corporate income tax rate
C) the foreign corporate dividend withholding tax rate
D) All of the above are important factors.
A) the Foreign corporate income tax rate
B) the U.S. corporate income tax rate
C) the foreign corporate dividend withholding tax rate
D) All of the above are important factors.
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31
TABLE 21.1
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. If MetroCity set the payout rate from the Ukraine subsidiary at 25%, how should MetroCity set the payout rate of the Korean subsidiary (approximately) to more efficiently manage its total foreign tax bill?
A) 28.5%
B) 24.5%
C) 42.6%
D) 82.3%
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. If MetroCity set the payout rate from the Ukraine subsidiary at 25%, how should MetroCity set the payout rate of the Korean subsidiary (approximately) to more efficiently manage its total foreign tax bill?
A) 28.5%
B) 24.5%
C) 42.6%
D) 82.3%
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32
Tax treaties typically result in ________ between the two countries in question.
A) lower property taxes for U.S. citizens overseas
B) elimination of differential tax rates
C) increased double taxation
D) reduced withholding tax rates
A) lower property taxes for U.S. citizens overseas
B) elimination of differential tax rates
C) increased double taxation
D) reduced withholding tax rates
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33
Instruction 21.1:
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. has no bilateral trade agreement with the host country, what is the total amount of income taxes Rogue River Exporters will pay?
A) $25,000
B) $35,000
C) $51,250
D) $60,000
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. has no bilateral trade agreement with the host country, what is the total amount of income taxes Rogue River Exporters will pay?
A) $25,000
B) $35,000
C) $51,250
D) $60,000
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34
Instruction 21.1:
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. treated the taxes paid on income earned in the host country as a tax-deductible expense, then Rogue River's total U.S. corporate tax on the foreign earnings would be ________.
A) $10,000
B) $26,250
C) $35,000
D) $51,250
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. treated the taxes paid on income earned in the host country as a tax-deductible expense, then Rogue River's total U.S. corporate tax on the foreign earnings would be ________.
A) $10,000
B) $26,250
C) $35,000
D) $51,250
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35
TABLE 21.1
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. How much in additional U.S. taxes would be due if MetroCity averaged the tax credits and liabilities of the two foreign units, assuming a 50% payout rate from each?
A) $3,750
B) $13,750
C) $2,500
D) $0
Uses the information to answer following question(s).
MetroCity Designs Inc., located in Northern California, has two international subsidiaries, one located in the Ukraine, the other in Korea. Consider the information below to answer the next several questions.

Refer to Table 21.1. How much in additional U.S. taxes would be due if MetroCity averaged the tax credits and liabilities of the two foreign units, assuming a 50% payout rate from each?
A) $3,750
B) $13,750
C) $2,500
D) $0
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36
Instruction 21.1:
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. has a bilateral trade agreement with the host country that calls for the total tax paid to be equal to the maximum amount that could be paid in the highest taxing country, what is the total amount of income taxes Rogue River Exporters will pay to the host country, and how much will they pay in U.S income taxes on the foreign earned income?
A) $25,000; $10,000
B) $25,000; $26,250
C) $35,000; $0
D) None of the above
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. has a bilateral trade agreement with the host country that calls for the total tax paid to be equal to the maximum amount that could be paid in the highest taxing country, what is the total amount of income taxes Rogue River Exporters will pay to the host country, and how much will they pay in U.S income taxes on the foreign earned income?
A) $25,000; $10,000
B) $25,000; $26,250
C) $35,000; $0
D) None of the above
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37
Transfer pricing is a strategy that may be used by MNEs to
A) reduce consolidated corporate income taxes.
B) partially finance a subsidiary in another country.
C) transfer funds from a subsidiary to the parent corporation.
D) all of the above.
A) reduce consolidated corporate income taxes.
B) partially finance a subsidiary in another country.
C) transfer funds from a subsidiary to the parent corporation.
D) all of the above.
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38
Some countries assess extremely low corporate income tax rates on foreign source income in order to
A) attract tax haven affiliates of foreign multinationals.
B) boost the value of their domestic currency.
C) support higher taxes of their domestic companies.
D) none of the above.
A) attract tax haven affiliates of foreign multinationals.
B) boost the value of their domestic currency.
C) support higher taxes of their domestic companies.
D) none of the above.
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39
Instruction 21.1:
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. treated the taxes paid on income earned in the host country as a tax-credit, then Rogue River's total U.S. corporate tax on the foreign earnings would be ________.
A) $51,250
B) $35,000
C) $26,250
D) $10,000
Use the information to answer following question(s).
Rogue River Exporters USA has $100,000 of before tax foreign income. The host country has a corporate income tax rate of 25% and the U.S. has a corporate income tax rate of 35%.
Refer to Instruction 21.1. If the U.S. treated the taxes paid on income earned in the host country as a tax-credit, then Rogue River's total U.S. corporate tax on the foreign earnings would be ________.
A) $51,250
B) $35,000
C) $26,250
D) $10,000
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40
The purpose of a withholding tax on dividend income is to
A) raise the effective as rate of the local host country.
B) provide an incentive for MNEs to pay higher dividends to their parent companies.
C) obtain a minimum tax payment on the incomes of dividend income receipts.
D) encourage MNEs to reposition profits outside of their countries.
A) raise the effective as rate of the local host country.
B) provide an incentive for MNEs to pay higher dividends to their parent companies.
C) obtain a minimum tax payment on the incomes of dividend income receipts.
D) encourage MNEs to reposition profits outside of their countries.
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41
What is a value-added tax? Where is this type of tax in wide usage? Why do you suppose this form of taxation has not been widely accepted in the United States?
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42
The U.S. Internal Revenue Service can reallocate revenues and expenses between parent corporations and their subsidiaries to more clearly reflect a proper allocation of income. In such instances it is the responsibility of the corporation to prove that the IRS has been arbitrary in its decision-making, thus establishing a "guilty until proved innocent" tax approach.
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43
________ is NOT an "arm's length price" method of determining transfer prices among parent and affiliated firms.
A) Comparable uncontrolled price method
B) Resale price method
C) Cost-plus method
D) All of the above are acceptable methods.
A) Comparable uncontrolled price method
B) Resale price method
C) Cost-plus method
D) All of the above are acceptable methods.
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44
Explain the worldwide and territorial approaches of national taxation. The authors state that the United States uses both approaches. How can this be? Give an example of each taxation approach.
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45
In the mid 1980s the U.S. led the way to higher corporate income tax rates worldwide. Today, most of the G7 nations have surpassed the U.S. and have higher corporate income tax rates than the U.S.
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46
Johnson Worldwide Aeronautics Inc., headquartered in the United States, is attempting to reduce the firm's consolidated total income taxes. The firm has just made a sale of parts to their affiliate in Lithuania, a country that has a corporate income tax rate of 15%. If the United States has a corporate income tax rate of 35%, which of the following transfer pricing strategies should Johnson attempt to follow?
A) Comparable parts were sold to a subsidiary in the United States for $1,000,000, therefore, Johnson should price the parts for $1,000,000.
B) If Johnson made an individual stand-alone sale of these parts on the open market the estimated price is $1,250,000. Therefore, this should be Johnson's price.
C) If Johnson were to allocate full costs including overhead and a reasonable profit on the sale, they could charge a total of $1,500,000. Therefore this should be Johnson's price.
D) Johnson's price to its affiliate makes no difference; the consolidated income taxes will be the same regardless of the transfer pricing technique used by the firm.
A) Comparable parts were sold to a subsidiary in the United States for $1,000,000, therefore, Johnson should price the parts for $1,000,000.
B) If Johnson made an individual stand-alone sale of these parts on the open market the estimated price is $1,250,000. Therefore, this should be Johnson's price.
C) If Johnson were to allocate full costs including overhead and a reasonable profit on the sale, they could charge a total of $1,500,000. Therefore this should be Johnson's price.
D) Johnson's price to its affiliate makes no difference; the consolidated income taxes will be the same regardless of the transfer pricing technique used by the firm.
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47
A foreign subsidiary has $2,000,000 of taxable income, a (foreign) corporate tax rate of 25%, and a foreign dividend withholding rate of 10%. The U.S. (domestic) parent has a corporate tax rate of 30%. What are the total taxes paid by the foreign subsidiary? Assume that the foreign subsidiary is 100% owned by the U.S. parent and that all after-tax income is paid to the U.S. parent.
A) $0.00
B) $650,000
C) $500,000
D) $1,350,000
A) $0.00
B) $650,000
C) $500,000
D) $1,350,000
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48
All indications are that the value-added tax will soon be the dominant form of taxation in the U.S.
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49
Among the G7 nations, the U.S. has a below average corporate income tax rate that makes it attractive for other countries to invest in the U.S.
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50
A foreign subsidiary has $2,000,000 of taxable income, a (foreign) corporate tax rate of 25%, and a foreign dividend withholding rate of 10%. The U.S. (domestic) parent has a corporate tax rate of 30%. What are the additional taxes paid by the U.S. domestic parent after the foreign subsidiary pays corporate and withholding taxes? Assume that the foreign subsidiary is 100% owned by the U.S. parent and that all after-tax income is paid to the U.S. parent.
A) $0.00
B) $600,000
C) $405,000
D) $250,000
A) $0.00
B) $600,000
C) $405,000
D) $250,000
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51
________ is the pricing of goods, services, and technology between related companies.
A) Among pricing
B) Retail pricing
C) Transfer pricing
D) Wholesale pricing
A) Among pricing
B) Retail pricing
C) Transfer pricing
D) Wholesale pricing
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52
The two basic approaches to national tax systems are
A) domestic and foreign.
B) worldwide and territorial.
C) high and low rates.
D) continental and global.
A) domestic and foreign.
B) worldwide and territorial.
C) high and low rates.
D) continental and global.
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