Final Exam Flashcards
What are the different approaches to entering the US market for a company?
US Subsidiary Corporation, Unincorporated US Branch Office, Other types of U.S prescence
When does a business have substantial nexus?
When taxpayer has physical presence
What two taxes does the federal government impose?
Business profits, investment type income
What is permanent establishment?
- fixed place of business situated in US
What’s excluded from permanent establishment?
(1) Use of us facilities solely to store, display or deliver inventory, (2) Presence in US of inventory solely for purpose of storage, display, or delivery, (3) Maintaining fixed place of business in U.S solely to purchase goods, collect information
How many states require apportioned income on a combined basis?
12 states
How long is a water edge election for?
7 years
How many states required the UDIPTA three factor format
9 states
What is a franchise tax?
Tax imposed just to do business in a state
How is franchise tax based?
apportioned capital, net worth, income, another non-income base
What are the four tests for nexus?
(1) doing business in state (2) commercial domicile in state (3) incorporated in state (4) qualified or registered to do business in the state
What is a unitary business group?
group of persons related through common ownership , group of persons are integrated with dependent upon and contribute to each other
What are the three types of credits and incentives
Statutory automatic, statutory pre-approved discretionary
What are investment tax credits?
Income tax credits generated through purchase and placing in service of qualified real and/or tangible personal property
What is nexus?
a means of connection, a link, or tie
