Which of the Following Transactions by a U

question 17

Multiple Choice

Which of the following transactions by a U.S.corporation may result in taxation under § 367.

• A)Incorporation of U.S branch as a U.S.corporation when the branch earns foreign-source income.
• B)Incorporation of a U.S.branch as a U.S.corporation if the new U.S.corporation has no foreign shareholders.
• C)Incorporation of a U.S.branch as a U.S.corporation if the new U.S.corporation also has foreign shareholders.
• D)All the above.
• E)None of the above.

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Definitions:

Enforceable Contract

An agreement between parties that is legally binding and may be upheld and compelled by law.

Mailbox Rule

A rule providing that an acceptance of an offer becomes effective on dispatch.

Air-conditioned Bus

A bus equipped with a system to cool and dehumidify the air, providing comfort to passengers.

Tour Group

A group of individuals organized for the purpose of traveling together, usually with a guide or planned itinerary.