Flora Corporation, a U.S. corporation that manufactures
imitation flowers owns 100% of the stock of Danica Corporation, a
foreign sales subsidiary that was organized in Year 1. It
contributed $2,000,000 in exchange for the Danica stock. During
Year 1, Danica had $60 million of foreign base company sales
income, paid $12 million in foreign income taxes, and did not
distribute any dividend. During Year 2, Danica had no earnings and
profits, paid no foreign income taxes, and distributed a $48
million dividend which was subject to 10% foreign withholding tax.
The U.S. corporate tax rate is 35%.
For Year 1, what is the amount of foreign source income that
Flora Corporation would include in its gross income and which
category of income would it be?
$48 million Active
$60 million Active
0
$72 million Passive
Flora Corporation, a U.S. corporation that manufactures imitation flowers owns 100% of the stock of Danica Corporation,
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