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Horton Corporation is a 100 percent owned Canadian subsidiary of Cruller Corporation, a U.S. corporation. During...

Horton Corporation is a 100 percent owned Canadian subsidiary of Cruller Corporation, a U.S. corporation. During the current year, Horton paid a dividend of C$603,750 to Cruller. The dividend was subject to a withholding tax of C$31,000. Assume an exchange rate of C$1 = $1. Cruller reported U.S. source taxable income of $2,050,000 before considering the dividend received from Horton Corporation. Compute the tax consequences to Cruller as a result of this dividend.

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Answer #1

As per the US Law,

The dividends-received deduction (DRD), under U.S. federal income tax law, is a tax deduction received by a corporation on the dividends it receives from other corporations in which it has an ownership stake.

Dividends received from an 80%-owned corporate subsidiary are exempt if certain conditions are met. Finally, if the company receiving the dividend owns more than 80% of the company paying the dividend, the DRD equates to 100% of the dividend.

In the given case, Horton Corporation owns 100% stake of Cruller Corporation which is more than 80%. As a result, the Dividend received of CS$ 603,750 is not taxable. Only the source Taxable Income of CS$2,050,000 is taxable.

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