ITS Core Competencies: Quiz

Who falls in scope for Corporate Alternative Minimum Tax (CAMT)?

• Corporations with $1 billion+ average annual adjusted financial statement income

• Corporations with $500 million+ average annual adjusted financial statement income

• Corporation with $1 billion+ average annual taxable income

• Corporations with $500 million+ average annual adjusted financial statement income

• All of the above

What is the maximum percentage of the deemed paid foreign tax credit related to the CFC’s GILTI that can be used to offset the US tax on the US shareholder’s GILTI?

• 0%

• 50%

• 80%

• 100%

The GILTI amount needs to be grossed up by the taxes attributable to the GILTI amount in order to get to the US shareholder’s GILTI inclusion. What is this gross-up amount referred to?

• Foreign tax credit

• The Section 250 gross-up

• The Section 78 gross-up

• GILTI gross-up

The full inclusion rule treats all of the CFC’s gross income as subpart F income if the foreign base company income exceeds at least what percentage of the CFC’s total gross income?

• 25% of the CFC’s total gross income

• 50% of the CFC’s total gross income

• 70% of the CFC’s total gross income

• 90% of the CFC’s total gross income

One way the manufacturing exception to FBCSI is satisfied is through the substantial contribution test. In general, what does the substantial contribution test require?

• CFC substantially contributes to the manufacture of the property

• CFC establishes a branch to conduct manufacturing operations

• US shareholder substantially contributes to the manufacture of the property

• US shareholder establishes a foreign branch to conduct manufacturing operations

Which form is required to be filed for the annual country-by-country reporting by certain U.S. persons that are the ultimate parent entity of a U.S. multinational enterprise (MNE) group with annual revenue for the preceding reporting period of $850,000,000 or more?

• Form 5713

• Form 8883

• Form 8975

• Form 8992

What form must corporations file to claim FTCs?

• Form 8858

• Form 1118

• Form 1120-F

• Form 5471

Deemed foreign tax credits exist with respect to which types of income?

• Subpart F income

• GILTI income

• Both subpart F income and GILTI income

A 'tested jurisdiction' may pass which of the following tests to qualify for the Transitional CbCR Safe Harbour?

• De minimis test

• Simplified ETR Test

• Routine Profits test

• Any of the above

A QDMTT will apply before CFC allocations and application of the IIR or UTPR.

• True

• False