ACC 559 Unit 6

1. Explain the mechanism that states use to prevent the double taxation of the income of a corporation doing business in two or more states.

2. Does a state have the authority to require a U.S.-based multinational corporation to compute its state taxable income on a worldwide combined reporting basis? What about a foreign-based multinational corporation? Explain.

3. The IRS is conducting a transfer pricing examination of USAco, a wholly-owned U.S. subsidiary of FORco. USAco purchases widgets from FORco for resale in the United States. The IRS examines USAco’s transfer pricing practices for a year in which the statute of limitations will expire in six months. With respect to FORco’s manufacturing costs, USAco has failed to reply to information document requests and a summons that is currently docketed in court for enforcement. What procedural tools may the IRS employ to obtain information regarding FORco’s manufacturing costs? Explain.

4. USAco is the wholly-owned U.S. subsidiary of ASIAco, a Japanese parent corporation that manufactures automobiles and sells them to USAco for resale in the United States. ASIAco sells the automobiles to USAco for $20,000 and USAco resells the automobiles for $21,000. After a lengthy transfer pricing examination, the IRS proposes an adjustment, based on what it believes is the arm’s length price that ASIAco should charge USAco of $17,000 per automobile. USAco would like to file a protest at Appeals, but is also considering seeking relief from the U.S. competent authority. What are USAco’s options? Explain.