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What US income tax issues must be considered

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Problem - Molly, Inc., a domestic corporation, generates income from the receipt of royalty income from patents that it owns. Molly wants to avoid U.S. income tax on these royalties, so it has its 100%-owned subsidiary, based in Nigeria, hold the patents and collect the royalties. What U.S. income tax issues must be considered in assessing this arrangement by Molly, Inc.?

Reference no: EM132664223

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