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DC, a domestic corporation, manufactures telephones for sale in the US and abroad. DC owns 100% of the stock of CTS, a Hong Kong sales subsidiary that was organized in Year 1.
For Year 1, CTS had $12 million sales income from selling telephones, manufactured by DC, to customers in Japan; $3 million interest income from US Treasury Notes; paid $3 million in foreign income taxes; and distributed no dividends.
During Year 2, CTS had no earnings and profits, paid no foreign income taxes, and distributed a $12 million dividend.
Assuming the U.S. corporate tax rate is 35%, what are the U.S. tax consequences of CTS’s Year 1 and Year 2 activities? Why?

Must use primary resources as citations only.



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