Annotated Bibliography Writing Services:   What is DC’s U.S. tax after the foreign tax credit?  Assume alternatively:

DC, a Delaware corporation, purchases goods manufactured in the United States by several related corporations and sells them in the United States and countries X and Y.  The sales in country X are made through a branch of DC in country X, and the country Y sales are made by an unrelated country Y corporation functioning as DC’s independent sales agent.  For the current taxable year, DC’s U.S. taxable income (determined without regard to foreign income taxes) is $1,000, of which $,100 is from the sales through the country X branch, $100 is from the sales to customers in country Y and $800 is from sales in the U.S.  DC’s U.S. tax before credit for foreign income taxes is $350.  Its country X tax for the year is $40.  It pays no country Y tax because it has no permanent establishment in that country.  What is DC’s U.S. tax after the foreign tax credit?  Assume alternatively:

A-    Title to all goods sold in countries X and Y passes to the buyers when the goods are delivered to a common carrier in Seattle.

B-    DC ships all goods to customers in countries X and Y from Seattle, but the sales contracts specify that title passes to these customers upon delivery in countries X and Y.

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