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In allocating interest expense between U.S.and foreign sources, a taxpayer elects to use either the tax basis of the income-producing assets or their fair market values.

A) True
B) False

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Nico lives in California.She was born in Peru but holds a green card.Nico is a nonresident alien NRA).

A) True
B) False

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Which of the following statements regarding income sourcing is not correct?


A) Concerning the foreign tax credit, most U.S.persons benefit from earning low-tax foreign-source income.
B) Foreign persons generally benefit from avoiding U.S.-source income classification.
C) U.S.persons are not concerned with source of income because all their income is subject to U.S.tax under a worldwide system.
D) Foreign persons may be subject to tax on U.S.-source income without regard to their actual presence in the United States.

E) C) and D)
F) A) and B)

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An assembly worker earns a $50,000 salary and receives a fringe benefit package worth $15,000.The payroll factor assigns $65,000 for this employee.

A) True
B) False

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In determining taxable income for state income tax purposes, interest income from Federal bonds typically constitutes an) modification.

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Under P.L.86-272, the taxpayer is exempt from state taxes on income resulting from the mere solicitation of orders for the sale of stocks and bonds.

A) True
B) False

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The IRS can use ยง 482 reallocations to assure that transactions between related parties are properly reflected in a tax return.

A) True
B) False

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The United States has in force income tax treaties with about 70 countries.

A) True
B) False

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Olaf, a citizen of Norway with no trade or business activities in the United States, sells at a gain 200 shares of MicroShift, Inc., a U.S.company.The sale takes place through Olaf's broker in Oslo.How is this gain treated for U.S.tax purposes?


A) It is foreign-source income subject to U.S.taxation.
B) It is foreign-source income not subject to U.S.taxation.
C) It is U.S.-source income subject to U.S.taxation.
D) It is U.S.-source income exempt from U.S.taxation.

E) C) and D)
F) B) and D)

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Without the foreign tax credit, double taxation would result when:


A) The United States taxes the U.S.-source income of a U.S.resident.
B) A foreign country taxes the foreign-source income of a nonresident alien.
C) The United States and a foreign country both tax the foreign-source income of a U.S.resident.
D) Terms of a tax treaty assign income taxing rights to the U.S.

E) B) and C)
F) A) and D)

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Waltz, Inc., a U.S.taxpayer, pays foreign taxes of $50,000 on foreign-source general basket income of $90,000.Waltz's worldwide taxable income is $450,000, on which it owes U.S.taxes of $94,500 before FTC.Waltz's FTC is $50,000.

A) True
B) False

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State Q wants to increase its income tax collections, but politically it would be unwise to raise taxes on in-state individuals or businesses.Q currently follows all UDITPA rules and employs an equally weighted three-factor apportionment formula.Q allocates nonbusiness income amounts. Identify some changes to the income tax apportionment formula that would shift the scheduled income tax increases to out-of-state businesses.

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โˆ™ Over-weighting the sales factor.
โˆ™ Sal...

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U.S.income tax treaties typically:


A) Provide for taxation exclusively by the source country.
B) Provide for taxation exclusively by the country of residence.
C) Provide rules by which multinational taxpayers avoid double taxation.
D) Provide that the country with the highest tax rate will be allowed exclusive tax collection rights.

E) C) and D)
F) None of the above

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U.S.income tax treaties can be described as:


A) Napoleonic.
B) Spoke-and-Wheel.
C) Balanced.
D) Bilateral.

E) A) and B)
F) A) and C)

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Match each of the following terms with the appropriate description, in the state income tax formula.Apply the UDITPA rules in your responses. -State-level NOL.


A) Addition modification
B) Subtraction modification
C) No modification

D) A) and B)
E) All of the above

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Peanut, Inc., a U.S.corporation, receives $500,000 of foreign-source interest income, on which foreign taxes of $5,000 are withheld.Peanut's worldwide taxable income is $900,000, and its U.S.Federal income tax liability before FTC is $270,000.What is Peanut's foreign tax credit?


A) $500,000
B) $275,000
C) $150,000
D) $5,000

E) B) and C)
F) A) and D)

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Almost all of the states allow treatment to an LLC for income tax purposes.

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flow-throu...

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Property taxes generally are collected by local taxing jurisdictions, not the state or Federal governments.

A) True
B) False

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A tax haven often is:


A) A country with high internal income taxes.
B) A country with no or low internal income taxes.
C) A country without income tax treaties.
D) A country that prohibits "treaty shopping."

E) All of the above
F) B) and C)

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Mitch, an NRA, sells a building in Omaha for $1 million.His basis in the building is zero for both regular tax and AMT purposes.Mitch has no other contact with the U.S.other than the ownership of the building.How much Federal income tax is due from Mitch on the sale?


A) $0, as Mitch is an NRA.
B) The amount realized times the top individual tax rate.
C) The net gain times the top capital gains tax rate.
D) The net gain taxed at the lesser of the applicable regular or AMT rates.

E) C) and D)
F) A) and C)

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