tax q

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1. Hans, a citizen and resident of Argentina, is a retired bank executive. Hans does not hold a green card. At the start of Year 1, Hans paid $2.5 million for a 20-unit apartment complex located in the suburbs of Washington, D.C. Hans does not actively manage the building, but rather leases it to an unrelated property management company that subleases the building to the tenants. During Year 1, Hans had rental income of $300,000 and operating expenses (depreciation, interest, insurance, etc.) of $220,000. On the advice of his accountant, Hans made a Code Sec. 871(d) election in Year 1. At the start of Year 2, Hans sold the building for $350,000. Hans’ adjusted basis in the building at that time was $290,000.

What are the U.S. tax consequences of Hans’ U.S. activities?

2. USAco, a domestic corporation, is a wholly-owned subsidiary of FORco, a foreign corporation. USAco’s only assets are cash of $200,000, accounts receivable of $200,000 and its U.S. manufacturing plant worth $500,000. USAco has no liabilities. FORco sells USAco to an independent U.S. buyer.

Is FORco’s sale of USAco subject to withholding under FIRPTA? Explain.

Would your answer change if USAco had a liability of $300,000 in the form of a mortgage on the U.S. manufacturing plant?

4. Wheelco, a foreign corporation, manufactures motorcycles for sale worldwide. Wheelco markets its motorcycles in the United States through Wheely, a wholly-owned U.S. marketing subsidiary that derives all of its income from U.S. business operations. Wheelco also has a creditor interest in Wheely, such that Wheely’s debt to equity ratio is 3 to 1, and Wheely makes annual interest payments of $60 million to Wheelco. The results from Wheely’s first year of operations are as follows:

Sales .............................................................................................	$180 million
Interest income ...............................................................................	$6 million
Interest expense (paid to Wheelco).................................................................................................	$6 million
Depreciation expense....................................... ..............................	($30 million)
Other operating expenses................................. ..............................	($81 million)
Pre-tax income ................................................. ............................	$15 million

Assume the U.S. corporate tax rate is 35%, and that the applicable tax treaty exempts Wheelco’s interest income from U.S. withholding tax. Compute Wheely’s interest expense deduction.