Question

1. Identify the 4 primary legal characteristics of a corporation.

2. Explain the difference between a tax deduction and a tax credit. Generally speaking, which is more advantageous and why.

3. What is the definition of a permanent establishment? What is the significance of a permanent establishment when used in connection with bilateral income tax treaties?

4. What is nexus? What determines nexus in connection with the state's ability to impose an income tax on a non-resident corporation?

5. What is the definition of a "pass-through entity" and name one advantage of setting up a business entity as a "passthrough"?

6. What activity is the U.S. tax law trying to encourage by imposing a lower tax on foreign-derived intangible income? What is the tax rate on that income?

Answer 1