Explain how the allocation and apportionment process works for the deduction.
a). Taxing Multinational Transactions”
• The source rules determine if an income or deduction is a US source or foreign source. Your client, Robin, is in her first year of business and is trying to get clarification on the source rules. Identify one source of income and one source of deduction and explain to Robin how its source is determined. Be sure to explain how the allocation and apportionment process works for the deduction.
b). The Wealth Transfer Decision”
• You are helping your client build a better understanding of the three types of transfer taxes. Identify one of the transfer taxes and explain the formula for that tax. In addition, please recommend any planning concepts that should be considered to minimize tax consequences.
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