USP, a domestic corporation, operates abroad through numerou…
USP, a domestic corporation, operates abroad through numerous foreign entities. In its first year of operations, USP reports the following results: USP operates in Country U through a 100%-owned foreign corporation that is a disregarded entity for U.S. tax purposes. This check-the-box branch reports $90,000 of taxable income and pays $25,000 of Country U corporate income taxes. USP’s 100%-owned Country V subsidiary reports $170,000 of taxable income, $34,000 of foreign income taxes, and current-year E&P of $136,000. All the E&P is Subpart F income. USP’s 100%-owned Country W subsidiary reports taxable income (non-Subpart F) of $180,000, pays $60,000 of foreign income taxes, and distributes a $120,000 dividend. Country W imposes a $7,000 withholding tax on the dividend. Thus, USP receives a payment of $113,000. What amount of net taxable income does USP report on line 30 of its Form 1120 because of these foreign entities?
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