Sushi Corporation Is a 100 Percent Owned Japanese Subsidiary of Squid,Inc.,a

question 4

Essay

Sushi Corporation is a 100 percent owned Japanese subsidiary of Squid,Inc.,a U.S.corporation.Sushi had post-1986 earnings and profits of ¥120,000,000 and post-1986 foreign taxes of $800,000.During the current year,Sushi paid a dividend of ¥60,000,000 to Squid.The dividend was characterized as general category income for FTC purposes.The dividend was subject to a 0 percent withholding tax.Assume an exchange rate of ¥1 = $0.010.Squid reported U.S.taxable income of $2,000,000.Squid's U.S.tax rate is 34 percent.Compute Squid's net U.S.tax liability for the current year and excess FTC,if any.

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Definitions:

Caveat Emptor

A legal principle meaning "let the buyer beware," implying that the buyer assumes the risk regarding quality or condition of the item purchased.

Ladino

A language, also known as Judeo-Spanish, spoken by descendants of Sephardic Jews who were expelled from Spain in 1492.

Central America

A geographical region in the Americas comprised of seven countries located between Mexico and South America.

Eastern Europe

A geographical and cultural region of Europe, traditionally comprising the countries east of Germany and west of the Ural Mountains.