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Assignment : International Taxation and Foreign Tax Credits
Write a four to six (4-6) page paper in which you:
Question 1: Based on your research, analyze the major impact of the Tax Cuts and Jobs Act on the use of controlled foreign corporations to expand abroad. Examine two (2) methods you would recommend to the client to circumvent the provisions of the Tax Cuts and Jobs Act on subpart F to reduce the client's tax liability. Provide at least two (2) examples to support your recommendations.
Question 2: Based on your research, create a plan for the client to lower taxes by reinvesting profits and thereby lower the company's tax liability. Provide at least one example to support your plan.
Question 3: Develop a strategy for the client to neutralize the impact of the Tax Cuts and Jobs Act on the immediate U.S. taxation of deferred income from foreign subsidiaries' earnings and profits (E&P) over an eight-year period. Provide examples to support your plan.
Question 4: Analyze the foreign tax credits available to your client. Propose at least three (3) tax credits the client could use and the impact of the credits on other foreign loss income. Provide examples to support your recommendations.
Hubbard argues that the Fed can control the Fed funds rate, but the interest rate that is important for the economy is a longer-term real rate of interest. How much control does the Fed have over this longer real rate?
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Your Corp, Inc. has a corporate tax rate of 35%. Please calculate their after tax cost of debt expressed as a percentage. Your Corp, Inc. has several outstanding bond issues all of which require semiannual interest payments.
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