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2. USAco, a domestic corporation, is a wholly-owned subsidiary of FORco, a foreign corporation. USAcos only assets are cash of $200,000, accounts receivable of $200,000
2. USAco, a domestic corporation, is a wholly-owned subsidiary of FORco, a foreign corporation. USAcos only assets are cash of $200,000, accounts receivable of $200,000 and its U.S. manufacturing plant worth $500,000. USAco has no liabilities. FORco sells USAco to an independent U.S. buyer. Is FORcos sale of USAco subject to withholding under FIRPTA? Explain. Would your answer change if USAco had a liability of $300,000 in the form of a mortgage on the U.S. manufacturing plant? 3. Cholati is a foreign corporation that produces fine chocolates for sale worldwide. Cholati markets it chocolates in the United States through a branch sales office located in New York City. During the current year, Cholatis effectively connected earnings and profits are $3 million, and its U.S. net equity is $6 million at the beginning of the year, and $4 million at the end of the year. In addition, a review of Cholatis interest expense account indicates that it paid $440,000 of portfolio interest to an unrelated foreign corporation, $200,000 of interest to a foreign corporation which owns 15% of the combined voting power of Cholatis stock, and $160,000 of interest to a domestic corporation. Compute Cholatis branch profi ts tax, and determine its branch interest withholding tax obligations. Assume that Cholati does not reside in a treaty country. Additional Requirements Level of Detail: Show all work
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