Question
Brewy is a foreign corporation that produces beer for sale worldwide. Brewy markets it beer in the United States through a U.S. limited liability company
Brewy is a foreign corporation that produces beer for sale worldwide. Brewy markets it beer in the United States through a U.S. limited liability company that is treated as a disregarded entity for U.S. tax purposes. The hybrid branch operates a sales office located in New York City. During the current year, Brewys effectively connected earnings and profits are $6 million, and its U.S. net equity is $12 million at the beginning of the year, and $8 million at the end of the year. In addition, a review of Brewys interest expense account indicates that it paid $320,000 of portfolio interest to an unrelated foreign corporation, $100,000 of interest to a foreign corporation, which owns 18% of the combined voting power of Brewys stock, and $240,000 of interest to a domestic corporation
Compute Brewys branch profits tax, and determine its branch interest withholding tax obligations. Assume that Brewy does not reside in a treaty country
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