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10-4 Out on a Limb Foreign Company (FC) is a 10% partner in a NY partnership. FC has no direct activities in the US. Is

10-4 Out on a Limb

Foreign Company (FC) is a 10% partner in a NY partnership. FC has no direct activities in the US. Is the NY partnership subject to the branch profits tax (BPT)? What about FC? If FC makes the sec 897(i) election, would it still be subject to the BPT?

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