Podcast
Questions and Answers
What is a key principle behind taxes paid by individuals and businesses?
What is a key principle behind taxes paid by individuals and businesses?
- Taxes paid must be fairly related to the services the state provides (correct)
- Taxes must be paid in cash only
- Taxes must be paid to the federal government only
- Taxes must be paid by a certain age
What determines the requirement for businesses to file income tax returns in a particular state?
What determines the requirement for businesses to file income tax returns in a particular state?
- Physical presence in the state (correct)
- Gross receipts or revenue
- Net income
- Sales and use tax nexus
What is the purpose of Public Law 86-272?
What is the purpose of Public Law 86-272?
- To impose income tax on all businesses
- To exempt small businesses from income tax
- To tax gross receipts or revenue
- To protect sellers of tangible personal property from income tax (correct)
What is a condition for a business to be protected from income tax liability under Public Law 86-272?
What is a condition for a business to be protected from income tax liability under Public Law 86-272?
What is another condition for a business to be protected from income tax liability under Public Law 86-272?
What is another condition for a business to be protected from income tax liability under Public Law 86-272?
What is true about the rules for determining income tax nexus and sales and use tax nexus?
What is true about the rules for determining income tax nexus and sales and use tax nexus?
What is the reason for Mark's sales agents to be on site in Utah?
What is the reason for Mark's sales agents to be on site in Utah?
Why did Mark reduce its normal fee for its copy center design team in Arizona?
Why did Mark reduce its normal fee for its copy center design team in Arizona?
Which type of tax return requires all members meeting the unitary criteria to be included, regardless of nexus?
Which type of tax return requires all members meeting the unitary criteria to be included, regardless of nexus?
Under what condition does a taxpayer participate in interstate commerce?
Under what condition does a taxpayer participate in interstate commerce?
What determines which businesses are required to file an income tax return in a state?
What determines which businesses are required to file an income tax return in a state?
What is protected by Public Law 86-272?
What is protected by Public Law 86-272?
In which state are Mark's orders approved?
In which state are Mark's orders approved?
What is considered a form of solicitation according to the Supreme Court?
What is considered a form of solicitation according to the Supreme Court?
Which states are unitary return states?
Which states are unitary return states?
What is the trade show rule related to?
What is the trade show rule related to?
What activity creates an income tax liability?
What activity creates an income tax liability?
What is not a protected activity under Public Law 86-272?
What is not a protected activity under Public Law 86-272?
In which state are dock sales typically sourced?
In which state are dock sales typically sourced?
What is included in the definition of payroll?
What is included in the definition of payroll?
How are property values determined for the purpose of the property factor?
How are property values determined for the purpose of the property factor?
Where are sales of services generally sourced?
Where are sales of services generally sourced?
What is the throwback rule related to?
What is the throwback rule related to?
How is payroll for each employee apportioned?
How is payroll for each employee apportioned?
Why do states require a negative adjustment for federal interest income?
Why do states require a negative adjustment for federal interest income?
What is the purpose of a positive adjustment for state income taxes in most states?
What is the purpose of a positive adjustment for state income taxes in most states?
How is state taxable income taxed when a business is taxable in only one state?
How is state taxable income taxed when a business is taxable in only one state?
What must an interstate business do with its business income and nonbusiness income?
What must an interstate business do with its business income and nonbusiness income?
What is the purpose of apportioning business income among states?
What is the purpose of apportioning business income among states?
What is the purpose of allocating nonbusiness income?
What is the purpose of allocating nonbusiness income?
What is the limitation on the creditability of foreign income taxes associated with Global Intangible Low-Taxed Income (GILTI)?
What is the limitation on the creditability of foreign income taxes associated with Global Intangible Low-Taxed Income (GILTI)?
What is the purpose of the gross-up amount under §78 in the GILTI basket?
What is the purpose of the gross-up amount under §78 in the GILTI basket?
What type of income is not eligible for deferral under the Tax Cuts and Jobs Act (TCJA)?
What type of income is not eligible for deferral under the Tax Cuts and Jobs Act (TCJA)?
What is the Worldwide ETR on the branch income calculated as?
What is the Worldwide ETR on the branch income calculated as?
What is the Excess 'limitation' calculated as?
What is the Excess 'limitation' calculated as?
What is the category of foreign source income that includes interest, certain dividends, rents, royalties, and annuities?
What is the category of foreign source income that includes interest, certain dividends, rents, royalties, and annuities?
What is the name of the test used to determine whether a foreign branch company has a substantial presence in the United States?
What is the name of the test used to determine whether a foreign branch company has a substantial presence in the United States?
What is the type of income that is subject to withholding taxes at the source?
What is the type of income that is subject to withholding taxes at the source?
What is the limitation on the current-year foreign tax credit in each category of foreign source income?
What is the limitation on the current-year foreign tax credit in each category of foreign source income?
What is the term for income earned through unincorporated business enterprises outside the United States?
What is the term for income earned through unincorporated business enterprises outside the United States?
Which of the following is a condition that Lars would meet to be considered a resident of Belgium for tax purposes?
Which of the following is a condition that Lars would meet to be considered a resident of Belgium for tax purposes?
What is the purpose of the foreign tax credit limitation in the U.S. tax system?
What is the purpose of the foreign tax credit limitation in the U.S. tax system?
In the U.S. tax system, what is the mechanism that prevents double taxation of foreign source income earned by a U.S. person?
In the U.S. tax system, what is the mechanism that prevents double taxation of foreign source income earned by a U.S. person?
What is the test used to determine if an individual has a substantial presence in a country for tax purposes?
What is the test used to determine if an individual has a substantial presence in a country for tax purposes?
What type of income is subject to withholding tax rates in the U.S. tax system?
What type of income is subject to withholding tax rates in the U.S. tax system?
What is the primary basis for taxing the worldwide income of U.S. citizens and residents?
What is the primary basis for taxing the worldwide income of U.S. citizens and residents?
What is the primary approach used by the United States in taxing its citizens and residents?
What is the primary approach used by the United States in taxing its citizens and residents?
Which type of income is taxed on a gross basis through a flat withholding tax?
Which type of income is taxed on a gross basis through a flat withholding tax?
What is the main purpose of the GILTI provision introduced in the Tax Cuts and Jobs Act?
What is the main purpose of the GILTI provision introduced in the Tax Cuts and Jobs Act?
What is the tax rate applicable to Effectively Connected Income (ECI) of a nonresident?
What is the tax rate applicable to Effectively Connected Income (ECI) of a nonresident?
Which of the following is a characteristic of the U.S. taxation of multinational transactions?
Which of the following is a characteristic of the U.S. taxation of multinational transactions?
What is the primary criterion used by the U.S. government to assert its right to tax a person or transaction?
What is the primary criterion used by the U.S. government to assert its right to tax a person or transaction?
What is the result of the move towards a territorial approach for U.S. corporations earning foreign-source income?
What is the result of the move towards a territorial approach for U.S. corporations earning foreign-source income?
What is the withholding tax rate applicable to Fixed, Determinable, Annual, or Periodical (FDAP) income of a nonresident?
What is the withholding tax rate applicable to Fixed, Determinable, Annual, or Periodical (FDAP) income of a nonresident?
What is the role of the foreign tax credit limitation in the U.S. taxation of multinational transactions?
What is the role of the foreign tax credit limitation in the U.S. taxation of multinational transactions?
What is the primary purpose of treaties in the context of international taxation?
What is the primary purpose of treaties in the context of international taxation?
How is interest expense allocated to gross income under the source rules for deductions?
How is interest expense allocated to gross income under the source rules for deductions?
What type of income taxes can be claimed as a credit on a U.S. tax return?
What type of income taxes can be claimed as a credit on a U.S. tax return?
What is the purpose of apportioning interest expense under the source rules for deductions?
What is the purpose of apportioning interest expense under the source rules for deductions?
What is the primary benefit of claiming a foreign tax credit on a U.S. tax return?
What is the primary benefit of claiming a foreign tax credit on a U.S. tax return?
What is the primary purpose of the source-of-income rules in multinational transactions?
What is the primary purpose of the source-of-income rules in multinational transactions?
How many categories of foreign source income are used to compute the FTC limitation?
How many categories of foreign source income are used to compute the FTC limitation?
Can an excess FTC arising in the GILTI basket be carried back or forward?
Can an excess FTC arising in the GILTI basket be carried back or forward?
What is the time period for carrying an excess FTC from the branch, passive, or general basket?
What is the time period for carrying an excess FTC from the branch, passive, or general basket?
What is the relationship between the 100% DRD and the FTC?
What is the relationship between the 100% DRD and the FTC?
In which basket of foreign source income is an excess FTC not allowed to be carried back or forward?
In which basket of foreign source income is an excess FTC not allowed to be carried back or forward?
What is the purpose of determining the jurisdictional source of gross income in multinational transactions?
What is the purpose of determining the jurisdictional source of gross income in multinational transactions?
How many tax years can an excess FTC be carried forward from the branch, passive, or general basket?
How many tax years can an excess FTC be carried forward from the branch, passive, or general basket?
What is the result of an excess FTC arising in the branch, passive, or general basket?
What is the result of an excess FTC arising in the branch, passive, or general basket?
What is the primary goal of the FTC limitation in multinational transactions?
What is the primary goal of the FTC limitation in multinational transactions?