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Phoenix Corporation Is a Controlled Foreign Corporation (CFC)incorporated in Country

question 15

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Phoenix Corporation is a controlled foreign corporation (CFC) incorporated in Country X.It is 100% owned by its U.S.parent corporation.Phoenix has $80,000 of taxable income from the sale of widgets that were purchased from their U.S.parent corporation.All widgets are intended for use or consumption within Country X and have the same gross profit.Sixty percent of the widgets were sold through a Country X wholesaler that is 100% owned by Phoenix,and 40% are sold through unrelated Country X wholesalers.What amount of profits will be constructively distributed as foreign-based company sales income to the U.S.parent company?


Definitions:

Partnership Agreement

A contract among partners in a business that outlines the terms and conditions of the relationship, including the distribution of profits and losses.

Intellectual Property

Legal rights that result from intellectual activity in the industrial, scientific, literary, and artistic fields, safeguarding creators' rights to their inventions, writings, music, and brands.

Limited Partners

Investors in a limited partnership who provide capital but have limited liability and are not involved in day-to-day management.

Admission

A statement made in court, under oath, or at some stage during a legal proceeding, in which a party against whom charges have been brought admits that an oral contract existed, even though the contract was required to be in writing.

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