Question regarding the interest expense deduction


Problem:

Wheelco, a foreign corporation, manufactures motorcycles for sale worldwide. Wheelco markets its motorcycles in the United States through Wheely, a wholly-owned U.S. marketing subsidiary that derives all of its income from U.S. business operations. Wheelco also has a creditor interest in Wheely, such that Wheely's debt to equity ratio is 3 to 1, and Wheely makes annual interest payments of $60 million to Wheelco. The results from Wheely's first year of operations are as follows:

  • Sales ............................................................................................. $180 million
  • Interest income ............................................................................... $6 million
  • Interest expense (paid to Wheelco).................................................................................. $60 million
  • Depreciation expense....................................... .............................. ($30 million)
  • Other operating expenses................................. .............................. ($81 million)
  • Pre-tax income ................................................. ............................ $15 million

Assume the U.S. corporate tax rate is 35%, and that the applicable tax treaty exempts Wheelco's interest income from U.S. withholding tax.

Required:

Compute Wheely's interest expense deduction.

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Accounting Basics: Question regarding the interest expense deduction
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