A US person that owns 10% or more of the total voting power or value of a foreign corporation.
What is a US shareholder?
For purposes of applying the $25M gross receipts test of the small business exemption, how often is testing required? (163j)
What is every tax year?
The location of where the International Tax Calculation, Data and Technology Services, Tier 1 Campaign materials are stored
What is Tax Source?
Name the two East Region Leaders
Who are Hadley Leach and David Wiseman
When properly allocable deductions exceed gross tested income.
What is tested loss?
What is 25%
The FDII deduction is reduced to 21.875% effective for:
A. Taxable years beginning after December 31, 2021.
B. Taxable years beginning before December 31, 2015.
C. Taxable years beginning after December 31, 2025.
D. Taxable years beginning after December 31, 2017.
What is C, Taxable years beginning after December 31, 2025.
The location of where the Extract, Transform, Load (ETL) Accelerator is stored?
What is Digital Lab?
This concept is described as expanding our natural alliance with advisory, increasing teaming within Tax LoS, and leveraging tax function of the future
What is One firm approach
The quarterly average of a CFC's adjusted basis in tangible depreciable property used in the CFC's trade or business
What is QBAI (qualified business asset investment)?
The FDII deduction is available to which types of taxpayers?
A. All corporations and partnerships
B. C corporations that are not RICs or REITs
C. C corporations and individuals
D. None of the above
What is B, C corporations that are not RICs or REITs
The name of the QST modeling tool
What is Beacon Platinum?
Name 3 out of the 5 PwC Network values
What are - Act with integrity, make a difference, care, work together, and reimagine the possible
DAILY DOUBLE
The US tax on GILTI can be partially offset by this amount of deemed paid foreign tax credit related to this CFC's GILTI.
What is 80%
True / False ...
Section 163(j) applies regardless of whether the interest payment is made to a US or foreign person, or whether the recipient of interest is exempt from US tax.
What is true?
The TRS product code for Data Accelerator engagements
What is US440?
Name three out of the six areas of focus for tax and finance in 2019
What is Adapting to US tax reform and policy changes, upskilling your workforce, aligning with customs and trade, embracing small automation, re-evaluating the operating structure, recognizing AI & Machine Learning
The value to be placed in the last row
What is $312,500?
Revenue: $5,000
Base Erosion % 21%
COGS ($450)
Modified TI $3,800
BEAT ($200)
Other ($750)
TI $3,600
Tax Rate 21%
Tax Rate 10%
Tax Exp $756
BEAT Tax $380
US Tax Expense $ ?
Corporation A has adjusted taxable income of $30,000, business interest income of $1,000 and interest expense of $12,000 with no floor plan financing interest for tax year 2018. What amount of interest expense can Corporation A deduct in 2018 and what amount can be carried forward to 2019 if any?
What is...
2018 interest deduction - 10,000
2019 carried forward amount - 2,000
The five phases of a Tax Reform Data Solutions Project
What is assessment, data inventory, design automation, approach, integrate, governance?
ERP/EPM - tax sensitization is a new offering of this TRS vertical
What is TRS for tax accounting