$($Assume that Country X has an income tax treaty in force with the United States that is identical to the U$.$S$.-$U$.$K$.$ Income Tax Treaty in all material respects and that Countries Y and Z do not have an income tax treaty in force with the United States. Any references to USCo, XCo, YCo, or ZCo are to companies that are incorporated in the United States, Country X$,$ Country Y$,$ or Country Z respectively. Unless otherwise indicated, assume that no entity is fiscally transparent in the United States or any other

country$\mathrm{.}3)$ XCo and YCo each own $50\%$ of ZCo. ZCo is fiscally transparent for purposes of Countries X and Y laws, but not in Country Z$.$ USCo pays a dividend to ZCo of $$100$ each. How much U$.$S$.$ tax must USCo withhold the dividend?