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IrishCo, a manufacturing corporation resident in Ireland, distributes products through a US office. Current year taxable income from such sales in the United States is $12million. IrishCo’s U.S office deposits working capital funds in short-term certificates of deposits with U.S. banks. Current year interest income from these deposits is $150,000. Irish Co also invests in U.S. securities traded on the New York Stock Exchange. This investing is done by the home office. For the current year, IrishCo records realized capital gains of $300,000 and dividend income of $50,000 from these stock investments. Compute Irish’s U.S. tax liability, assuming that the U.S.-Ireland income tax treaty reduces with holding on dividends to 15% and on interest to 5%. Assume a 34% U.S.tax rate

IrishCo, a manufacturing corporation resident in Ireland, distributes products through a US office.  Current year taxable income from such sales in the United States is $12million.  IrishCo’s U.S office deposits working capital funds in short-term certificates of deposits with U.S. banks.  Current year interest income from these deposits is $150,000.
Irish Co also invests in U.S. securities traded on the New York Stock Exchange.  This investing is done by the home office.  For the current year, IrishCo records realized capital gains of $300,000 and dividend income of $50,000 from these stock investments.  Compute Irish’s U.S. tax liability, assuming that the U.S.-Ireland income tax treaty reduces with holding on dividends to 15% and on interest to 5%.  Assume a 34% U.S.tax rate

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