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 tax provision for interim periods related to ordinary income (or loss) is computed by using rate?
What is an estimated AETR?
Name the East Regional Tax Managing Partner Leader
Who is Carin Giuliante?
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.
What items are recognized discretely in an interim reporting period? Name 3 items
What are out-of-period adjustments, loss jurisdictions, non-estimable pretax income items, items reported net of tax, share-based payment awards?
The IRS received more than 146 million individual income tax returns in one year. What percentage of these returns were filed electronically?
What is 30%?
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 TCJA modified aspects of NOL carryforwards. What are the new rules surrounding carryforwards and carrybacks of NOLs?
What is an indefinite carryforward?
Although corporate AMT has been repealed, companies can continue using AMT credits to offset any regular income tax liability through what years?
What is 2018 - 2020?
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?
What are the four subtopics of ASC740?
What is overall, intraperiod tax allocation, other considerations and special areas, and interim reporting?
How should existing AMT credit carryovers be presented on the balance sheet?
What is a receivable?
OR
What is a valuation allowance?
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
This Accounting Standard Update requires entities to present DTAs and DTLs as noncurrent in a classified balance sheet.
What is ASU 2015-17?
The TCJA modifies IRC Section 162(m) to include which position as a covered employee?
What is a CFO?