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Is anyone else so done with Becker???? I am studying for REG and am on Chapter 3 HW for C-Corps (which is 156 questions)… not only has it taken me ~4 hours….but half of the questions are 1) not covered by the lecture 2) ARE NOT PHYSICALLY IN THE BOOK. As a result, I am only getting around a 70% WITH THE BOOK OPEN. Does anyone have any recommendations as to what study materials to perhaps switch over to? After having this same issue with FAR (and as a result, having no strong basis in what was important/memorizing all these RANDOM facts that didn’t show up on my exams…), I want to look into other options.
EX: In which of the following situations will a controlled foreign corporation located in Ireland be deemed to have subpart F income?
a.
Property is produced in Ireland by the Irish company and sold outside its country of incorporation.
b.
Property is bought from the controlled foreign corporation’s U.S. parent and is sold by an Irish company for use in an Irish manufacturing plant.
c.
Services are provided by an Irish company in England under a contract entered into by its U.S. parent.
d.
Services are performed in Ireland by the Irish company under a contract entered into by its U.S. parent.
Explanation
Choice “c” is correct. Subpart F income is taxable income includable by a U.S. taxpayer from a controlled foreign corporation. It generally includes income that has no economic connection to the country of origin. This choice describes subpart F income, because the contract is entered into by the U.S. parent and has no economic connection to Ireland.
Choices “a”, “d”, and “b” are incorrect, because all of these transactions do have an economic connection to Ireland.WHERE WAS THERE EVER ANYTHING ON SUBPART F INCOME??? Ok sorry, psycho rant over. But this is ridiculous.
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