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Question - Foreign Tax Credit Limitation. Tucson, a U.S. corporation organized in Year 1, reports the following items for a three-year period.
Year 1
Year 2
Year 3
Foreign tax accrual
$70,000
$120,000
$180,000
Foreign source taxable income
400,000
300,000
500,000
Worldwide taxable income
1,000,000
The foreign source and worldwide taxable income items are determined under U.S. law.
a. What is Tucson's foreign tax credit limitation for each of the three years (assume a 21% U.S. corporate tax rate and that income from all foreign activities fall into a single basket)?
b. How are Tucson's excess foreign tax credits (if any) treated? Do any carryovers remain after Year 3?
c. How would your answers to Parts a and b change if the IRS determines that $100,000 of expenses allocated to U.S.-source income should have been allocated to foreign source income?
d. What measures should Tucson consider if it expects a potential current excess foreign tax credit position to persist in the long-run?
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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