Fendrich Comprehensive TCJA Assignment In 2018, Fendrich Inc. (a U.S. taxpayer) generated revenues of $500...
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Fendrich Comprehensive TCJA Assignment In 2018, Fendrich Inc. (a U.S. taxpayer) generated revenues of $500 million and incurred tax-deductible expenses of $410 million, resulting in U.S. taxable income of $90 million. Expenses include royalty payments and other base erosion payments, made to their offshore subsidiary FendBarb, amounting to $110 million. The Fendrich group as a whole averages more than $500 milion revenue per year. In 2018, FendBark. (In Barbados) had QBAI of $50 million and recognized $225 million revenue with $65 million in operating expenses. EendBarb's average corporate income tax rate is 1.2%. Eendaard was created as a wholly owned subsidiary in 2001 in Barbados. FendBarb has reported accumulated pre-tax earnings for the period 2001-2017 at $2,800 million. Accumulated pre-tax earnings allocated to the "held in cash" category is $2,000 million. None of the earnings generated by Fendfarbe have been repatriated back to Fendrich Inc. Although a portion of income generated by EendBarb is passive income, it has managed to avoid being treated as subpart Fincome. Any tax liability resulting from the DRAFE provision will be paid over the allowable 8-year period. Determine the amount of 2018 U.S. income tax liability for Fedrich. U.S. regular Income tax and the BEAT DRAFE, and GILTI provisions of the 2017 TCJA. Be sure to provide supporting calculations and analysis. Record your answers below: + TCIA Provision Net 2018 U.S. Tax Liability (after applicable FTC) $x.x (million) Regular Income tax BEAT DRAFE GILTI TOTAL Supporting Calculations: Fendrich Comprehensive TCJA Assignment In 2018, Fendrich Inc. (a U.S. taxpayer) generated revenues of $500 million and incurred tax-deductible expenses of $410 million, resulting in U.S. taxable income of $90 million. Expenses include royalty payments and other base erosion payments, made to their offshore subsidiary FendBarb, amounting to $110 million. The Fendrich group as a whole averages more than $500 milion revenue per year. In 2018, FendBark. (In Barbados) had QBAI of $50 million and recognized $225 million revenue with $65 million in operating expenses. EendBarb's average corporate income tax rate is 1.2%. Eendaard was created as a wholly owned subsidiary in 2001 in Barbados. FendBarb has reported accumulated pre-tax earnings for the period 2001-2017 at $2,800 million. Accumulated pre-tax earnings allocated to the "held in cash" category is $2,000 million. None of the earnings generated by Fendfarbe have been repatriated back to Fendrich Inc. Although a portion of income generated by EendBarb is passive income, it has managed to avoid being treated as subpart Fincome. Any tax liability resulting from the DRAFE provision will be paid over the allowable 8-year period. Determine the amount of 2018 U.S. income tax liability for Fedrich. U.S. regular Income tax and the BEAT DRAFE, and GILTI provisions of the 2017 TCJA. Be sure to provide supporting calculations and analysis. Record your answers below: + TCIA Provision Net 2018 U.S. Tax Liability (after applicable FTC) $x.x (million) Regular Income tax BEAT DRAFE GILTI TOTAL Supporting Calculations

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