Question
A, a U.S. income tax nonresident alien, has the following U.S. source fixed or determinable, annual or periodical income which is not otherwise effectively connected
A, a U.S. income tax nonresident alien, has the following U.S. source fixed or determinable, annual or periodical income which is not otherwise effectively connected with the conduct of a U.S. trade or business:
(i) $10,000 in dividends from a Florida corporation which does all of its business in Florida;
(ii) $30,000 of interest income on certificates of deposit with a Florida bank;
(iii) $20,000 of interest from FLACO, a Florida corporation, which meets the 80% foreign business requirements test of IRS 861(c); and
(iv) $15,000 of interest from FLACO, a Florida corporation, owned 91% by As U.S. income tax resident alien father and 9% by A.
Which of these items of income are exempt from U.S. withholding tax?
a. (i) and (ii)
b. (ii) and (iii)
c. (i) and (iii)
d. (iv)
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