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ABC Corporation is a US corporation that made a dividend payment to its parent, a foreign partnership. The foreign partnership has two equal owners. A

ABC Corporation is a US corporation that made a dividend payment to its parent, a foreign partnership. The foreign partnership has two equal owners. A Corp., the first corporate owner, is a resident of a country with a tax treaty with the United States that is identical to the US Model Treaty. B, the second individual owner, is a resident of a country with no tax treaty with the United States.

Please assume that the United States recognizes the foreign partnership as a partnership, and not as a corporation.

If ABC pays a dividend payment to the foreign partnership of $100,000, how much cash will A Corp receive if the dividend is distributed by the partnership to its owners upon receipt of the cash?

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