Multijurisdictional tax (Inbound taxation and Outbound taxation assignment)

Multijurisdictional tax (Inbound taxation and Outbound taxation assignment) Essay example
Masters
Essay
Finance & Accounting
Pages 12 (3012 words)
Download 0
TX 604 Spring 2013 Assignment 4 Inbound & Outbound Due Date: April 15th @4:00pm Email to sthoma1@bentley.edu Inbound Taxation Please read the following fact patterns and answer the questions that follow. John Doe, Flick’s tax director has contacted you. Some of the officers of one of Flick’s foreign subsidiaries have been calling him to ask a variety of US tax questions based on their (the officers – not the subsidiary) increased activity in the US…

Introduction

IBM Corporation pays a regular quarterly dividend on the stock. Your previous research concluded that Joe T. is a nonresident alien of the US. 1. Is the income received US source income or foreign source income? What statute did you rely on for your conclusion(s)? Facts Joe T. is a non resident alien of the United States who has invested in 1,000 shares of common stock in IBM Corporation. IBM is registered in Delaware, United States and does most of its business within the United States. The stock owned by Joe T. represents less than 1% of the overall value of IBM Corporation. Interpretation Joe T. is a non resident alien in the United States which means that Joe T.’s income derived from sourced within the United States are liable to taxation. Since IBM Corporation executes most of its business from within the United States, so under Sections 861(a)(2) and 862(a)(2), the dividends released by such businesses are considered as income being derived from within the United States. ...
Download paper
Not exactly what you need?

Related papers

Taxation
50,760.34 Salary - Tax - NIC Tax brackets Income 10% (starting rate for savings only) 0 - ?2,560 20% for basic rate 0 - ?35,000 40% for higher rate ?35,001 - ?150,000 50% for additional rate Over ?150,000 (HM revenue and Customs 480 (2011) The liability of income tax payable from the above computation is ?25,718.3. A deduction of personal allowance of 7,475 is made in the year 2011/2012 (Great…
Taxation
Whether someone is employed or self employed depends upon the terms and conditions of relevant engagement. The tax and National Insurance contributions (NICs) rules do, however have special rules that apply to certain special categories of workers in certain circumstances. If you work for someone else it is important to know whether you are working for that person in employed capacity or in a…
Taxation
If anyone has an income below the income tax personal allowance, he is not supposed to pay any tax however if the earnings of an individual is above the tax allowance then he is supposed to pay according to his earnings above this level. There are different tax bands and every tax band has a different tax rate (Income Tax Rates and Allowances). Corporation tax Corporation tax refers to the tax on…
Taxation
Back in 2002, the government introduced new reforms on company cars. The company car tax reform encourages people to buy of choose cars with lower levels of carbon dioxide (CO2) emissions. Purposely, the reforms are aimed at tackling changes in climate and greenhouse gas emissions. Also, it also encourages manufacturers to introduce greener cars. As a result, businesses should evaluate their…
Taxation
These two systems worked independently in the past and the tax authorities maintained separate tax systems for income tax and national insurance contributions. Income tax was taxed annually in a progressive manner on individuals and corporate bodies whereby low income earners were taxed lower than high income earners (UK Government, 2012). The tax rates increased with increase in incomes of…
Assignment 3: International Taxation and Foreign Tax Credits
This will in effect be a form of double taxation (Hines & Rice, 1994). A strategy for a US-Based taxpayer to repatriate earnings from the foreign markets and avoid or mitigate the U.S. tax impact on repatriation Lots of profits that most taxpayers in the U.S attribute to mitigate or avoid taxes should be taxed up to about 35% when they are repatriated. In this context, the client can repatriate…
International Taxation - International Taxation and Foreign Tax Credits
However, in reality the U.S. government ignores this concept of neutrality and imposes taxation on profits earned by U.S. companies in any country outside the border. Thus, U.S. companies who seek to spread businesses overseas are burdened with a combination of tax systems. Such companies are required to pay taxes to the U.S. Government as well as the government of the countries where they are…