Assignment 1 Unit 5 -Dougco, a domestic corporation

Assignment 1: Unit 5 ProblemsIn each of the following independent situations involving transfers of tangible property, determine which transfer pricing methods applies and compute a transfer price using the appropriate method. Show all of your computations.Dougco, a domestic corporation, owns 100% of Thaico, a Thailand corporation. Dougco manufactures top-of-the-line office chairs at a cost of $300 per unit and sells them to Thaico, which resells the goods (without any further processing) to unrelated foreign customers for $450 each. Independent foreign distributors typically earn commissions of 20% (expressed as a percentage of the sales price) on the purchase and resale of products comparable to those produced by DougcoClairco, a domestic corporation, owns 100% of Shuco, a foreign corporation that manufactures women’s running shoes at a cost of $30 each and sells them to Clairco. Clairco attaches its trade name to the shoes (which has a significant effect on their resale price), and resells them to unrelated customers in the United States for $80 each. Independent foreign manufacturers producing similar running shoes typically earn a gross profit markup (expressed as a percentage of the manufacturing costs) of 15%.Tomco, a domestic corporation, owns 100% of Swissco, a Swiss corporation. Tomco manufactures riding lawn mowers at a cost of $2,500 per unit, and sells them to unrelated foreign distributors at a price of $3,750 per unit. Tomco also sells the equipment to Swissco, which then resells the goods to unrelated foreign customers for $4,250 each. The conditions of Tomco’s sales to Swissco are essentially equivalent to those of the sales made to unrelated foreign distributors.USAco, a domestic corporation, owns all of the stock of FSub, a foreign corporation. FSub manufactures widgets and sells them at a price of $100 to USAco, which then resells the widgets to U.S. customers. USAco’s gross receipts for the year are $200 million.Under what circumstances would USAco be potentially subject to the Code Sec. 6662(e) substantial valuation misstatement penalty?Erica is a citizen of a foreign country, and is employed by Fco, a foreign corporation that manufactures industrial equipment. Fco does not have a permanent establishment in the United States. Erica’s job is to provide technical assistance to customers who purchase Fco’s products. Many of Erica’s customers are located in the United States. Consequently, Erica consistently spends about 120 working days per year in the United States. Erica does not possess a green card. Assume that the United States has entered into an income tax treaty with Erica’s home country that is identical to the United States Model Income Tax Convention of November 15, 2006.How does the United States tax Erica’s activities?Finco is a wholly-owned Finnish manufacturing subsidiary of Winco, a domestic corporation that manufactures and markets residential window products throughout the world. Winco has been Finco’s sole shareholder since Finco was organized in 2010. At the end of the current year, Winco sells all of Finco’s stock to an unrelated foreign buyer for $25 million. At that time, Finco had $6 million of post-1986 undistributed earnings, and $2 million of post-1986 foreign income taxes that have not yet been deemed paid by Winco. Winco’s basis in Finco’s stock was $5 million immediately prior to the sale.Assume Winco’s capital gain on the sale of Finco’s stock is not subject to any foreign taxes, and that the U.S. corporate tax rate is 35%. What are the U.S. tax consequences of this sale for Winco?Now assume that instead of selling the stock of Finco, Winco completely liquidates Finco, and receives property with a market value of $25 million in the transaction. As in the previous scenario, at the time of the liquidation, Finco had $6 million of accumulated earnings and profits, and $2 million of foreign income taxes that have not yet been deemed paid by Winco.Assume that Winco’s basis in Finco’s stock was $5 million immediately prior to the liquidation, and that the United States corporate tax rate is 35%. What are the United States tax consequences of this liquidation for Winco?Directions for Submitting your AssignmentCompose your Assignment in a Microsoft Word document and save it as Username AC559 Assignment 1 Unit 5.doc (Example: TAllen AC559 Assignment 1 Unit 5.doc). Submit your file by selecting the Unit 5: Assignment 1 in the Dropbox by the end of Unit 5.Assignment 2: Part 2 of Course PaperIn Unit 5, you will be submitting Part Two (Tax Planning Considerations for the Organization to Expand Abroad) of your Course Paper. Please review the Course Paper information below.Make sure you are thorough in your analysis and recommendation of the form of entity you suggest that USco choose for expansion. Comment on any applicable foreign tax laws, tax rates, and withholding taxes. Your paper should include references to transfer pricing requirements related to your selected country, as well.Make sure you meet the guidelines set below for formatting.Course Paper:For the Course Paper, you will engage in tax planning research culminating in two reports that will be submitted to the CEO of USco, a United States Corporation. The first report will involve tax planning issues related to the organization’s employees and will be due in Unit 4. The second report will involve tax planning issues related to the organization itself with respect to proposed international operations and will be due in Unit 5.USco designs and manufactures specialized equipment used in various manufacturing applications. The organization is contemplating expanding its operations overseas. The CEO has questions concerning the form of expansion (branch office, subsidiary, etc.) and the impact on employees (U.S. citizens living abroad, Nonresident aliens, resident aliens, etc.) and the tax implications for the organization itself.For purposes of this Assignment, you will select your own country of interest for the proposed expansion. Make sure that your selected country is one that has a tax treaty with the United States. You can find a listing of these tax treaty countries at the IRS website (www.irs.gov). Click on the business link, then international businesses. You will find tax treaties as one of the international business topics.You will want to use the textbook, IRS website, and the professional literature to determine relevant information that should be contained in each report. Your completed reports should be well-organized, well-documented, and clearly focused on the relevant issues appropriate to the course project. Each report should conform to the following parameters:Include a Title PageIntroductionBodyConclusionExecutive SummaryReference list5–10 pages in length (excluding title page and reference list)Use current APA formatDirections for Submitting your PaperCompose part two of your Course Paper in a Microsoft Word document and save it as Username AC559 Assignment 2 Unit 5.doc (Example: TAllen AC559 Assignment 2 Unit 5.doc). Submit your file by selecting the Unit 5: Assignment 2 Dropbox by the end of Unit 5.

Calculate the price
Make an order in advance and get the best price
Pages (550 words)
$0.00
*Price with a welcome 15% discount applied.
Pro tip: If you want to save more money and pay the lowest price, you need to set a more extended deadline.
We know how difficult it is to be a student these days. That's why our prices are one of the most affordable on the market, and there are no hidden fees.

Instead, we offer bonuses, discounts, and free services to make your experience outstanding.
How it works
Receive a 100% original paper that will pass Turnitin from a top essay writing service
step 1
Upload your instructions
Fill out the order form and provide paper details. You can even attach screenshots or add additional instructions later. If something is not clear or missing, the writer will contact you for clarification.
Pro service tips
How to get the most out of your experience with Essay Fountain
One writer throughout the entire course
If you like the writer, you can hire them again. Just copy & paste their ID on the order form ("Preferred Writer's ID" field). This way, your vocabulary will be uniform, and the writer will be aware of your needs.
The same paper from different writers
You can order essay or any other work from two different writers to choose the best one or give another version to a friend. This can be done through the add-on "Same paper from another writer."
Copy of sources used by the writer
Our college essay writers work with ScienceDirect and other databases. They can send you articles or materials used in PDF or through screenshots. Just tick the "Copy of sources" field on the order form.
Testimonials
See why 20k+ students have chosen us as their sole writing assistance provider
Check out the latest reviews and opinions submitted by real customers worldwide and make an informed decision.
Professional Writing Engl-3311
Thank you
Customer 452919, March 2nd, 2023
Sociology
Thank you
Customer 452919, September 2nd, 2024
History
Thanking you all in advance for your assistance.
Customer 452919, November 26th, 2024
Criminal Justice
Very well and a good paper. Well worded and organized. I would like to know where the references come from
Customer 452519, June 13th, 2020
Sociology
Thank you Team!
Customer 452919, April 5th, 2022
Psychology
Paper wad received on time there was also support with revision.
Customer 453101, June 8th, 2022
Arts and Applied Science
Thank you, I will provide more details after the discussion is graded.
Customer 452919, February 1st, 2025
Education
Great Job !!
Customer 453117, September 17th, 2022
Psychology
Thank you very much! I will be using your service again soon.
Customer 452665, March 18th, 2021
Education
Very well written thank you
Customer 452667, April 8th, 2021
Sociology
The writer covered all points as expected by the professor. Thank you for your commitment to serve students.
Customer 452919, February 21st, 2024
Sociology
Thank you, the journal wa submitted today and I hope to continue receiving services.
Customer 452919, October 28th, 2021
11,595
Customer reviews in total
96%
Current satisfaction rate
3 pages
Average paper length
37%
Customers referred by a friend
OUR GIFT TO YOU
15% OFF your first order
Use a coupon FIRST15 and enjoy expert help with any task at the most affordable price.
Claim my 15% OFF Order in Chat