International Tax
What is a CFC?
Controlled Foreign Corporation - a foreign corporation with more than 50% of its stock owned by one or more US persons who own at least 10% of its stock.
What percentage is the GILTI deduction?
50%
What is the FDII deduction percentage?
37.5%
What is the applicable IRC section for GILTI?
951A
What is the Foreign Tax Pool haircut on GILTI?
80%
Can you get a GILTI deduction if you have taxable income?
No, if you have no TI, you cannot utilize the deduction.
Can you get a FDII deduction if you have no taxable income?
No, if you have no TI, you cannot utilize the deduction.
When did TPC Partners buy ownership rights from Waud Capital?
April 2016
What is Subpart F income?
Income earned by a CFC that is to or from a related party.
Can you carryforward GILTI foreign taxes paid?
No, you use them or lose them.
What is the shape on the TPC logo?
Doric Column Capital
Is Subpart F included in GILTI?
No, it's an exception.
When was TPC founded?
2005
What is a good estimate of your foreign tax pools?
Current tax provision
What form would you file as a disregarded entity?
Form 8858
Where on the balance sheet would you find QBAI?
What form would you file as a CFC?
Form 5471
In order to be subject to BEAT, how much do you have to have in annual gross receipts?
$500 Million
What TPC client has an award-winning country song written about it?
Dart Containers
One of their most recognizable products, a Red Solo Cup, is the subject and name of the famous country song written by Toby Keith.
What percentage of TPC is made up of Millennials?