A Company Limited, a private limited company organized in India, is a software consulting firm. In 2018 A Company Limited established a U.S. subsidiary as a Delaware C corporation. During 2019 A Company Limited entered into several transactions and they've asked you to comment on the U.S. tax ramifications/implications of each. When reviewing please consider all potential U.S. tax issues such as sourcing of income, U.S. tax reform, withholding taxation, U.S. trade or business, effectively connected income and permanent establishment

a)A Company Limited loaned USD $5,000,000 to its U.S. subsidiary and is charging them an annual arm's length interest rate of 3%.

b)A Company Limited contracted with its largest U.S. customer directly and performed all services under the contract physically within India. The U.S. customer remunerated A Company Limited directly for the provision of such services.

c)The U.S. subsidiary declared and distributed a dividend to A Company Limited of $1,000,000.

d)Due to staffing constraints at the U.S. subsidiary, A Company Limited sent local employees directly to the U.S. (I.e., these local employees were not seconded to the U.S. subsidiary) to perform services under a contract. These employees were physically present in the Commonwealth of Massachusetts for 4 months and returned to India upon completion of the contract.