Inbound tax questions, T or F and why
True / False Questions (30 points total, 5 points per question)
- For taxable years beginning during the years 1993 through 2017, Internal Revenue Code (IRC) section 163(j) only limited a corporation’s ability to pay deductible interest to shareholders and other related persons.
- Due to changes brought by U.S. tax reform taxpayers with an overall domestic loss (ODL) per IRC section 904(g) are now required to recharacterize 100% of an ODL as foreign source income.
- Per IRC section 59A, under the Base Erosion & Anti-Abuse Tax or BEAT, an applicable taxpayer is defined as a taxpayer which is a corporation (other than a real estate investment trust, a regulated investment company or an S corporation), the average annual gross receipts of which for the three year taxable period ending with the preceding taxable year are at least $500,000,000 or the base erosion percentage of which for the taxable year is 3%.
- The objective of Section 884 is to make the tax result the same for a foreign person that conducts its U.S. business through a U.S. branch as it would be for a foreign person that conducts its U.S. business through a U.S. corporation.
- If the election under Section 871(d) is made, all income from real property located in the United States and held for the production of income is treated as income that is effectively connected with a U.S. trade or business.
- Stock of a domestic corporation is generally a U.S. real property interest unless the taxpayer shows that the corporation was not a U.S. real property holding corporation at any time during the shorter of (1) the period the taxpayer held the stock, or (2) the five years preceding the disposition of the stock.
T?F, and explain why in a short way