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.

$(1)$ XCo owns less than $10\%$ of the shares of USCo. XCo is wholly owned by YCo. YCo has one class of

shares, which is regularly traded on the New York Stock Exchange. How much U$.$S$.$ federal income tax, if

any, must USCo withhold on a dividend distribution of $$100,000$ to XCo? Why?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.

$(1)$ XCo owns less than $10\%$ of the shares of USCo. XCo is wholly owned by YCo. YCo has one class of

shares, which is regularly traded on the New York Stock Exchange. How much U$.$S$.$ federal income tax, if

any, must USCo withhold on a dividend distribution of $$100,000$ to XCo? Why?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.

$(1)$ XCo owns less than $10\%$ of the shares of USCo. XCo is wholly owned by YCo. YCo has one class of

shares, which is regularly traded on the New York Stock Exchange. How much U$.$S$.$ federal income tax, if

any, must USCo withhold on a dividend distribution of $$100,000$ to XCo? Why?