Question
A, a U.S. income tax nonresident alien from Country X, owns 100% of FC, a calendar year foreign company whose sole asset is a Dallas,
A, a U.S. income tax nonresident alien from Country X, owns 100% of FC, a calendar year foreign company whose sole asset is a Dallas, Texas shopping center, an active trade or business. At the close of the 2021 calendar year, FC has a net operating loss carryover of $200,000 and has no change in its U.S. net equity from December 31, 2021 to December 31, 2022. FC has a 2022 dividend equivalent amount of $90,000 (which amount also represented FC's pre-tax net income). FC's dividend equivalent amount would have been $120,000 had it not been for a $30,000 interest payment to A. The combined 2022 branch profits tax and branch level interest U.S. withholding tax FC will be responsible for is:
$36,000
$27,000
$9,000
$0
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