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CandyCo is a foreign corporation that makes taffy for sale worldwide. CandyCo markets its candy in the United States through a U . S .
CandyCo is a foreign corporation that makes taffy for sale worldwide. CandyCo markets its candy in the United States through a US subsidiary. A review of the US subsidiary's interest expense account indicates that it paid $ of interest to an unrelated foreign corporation on debt that is unassignable, $ of interest to a foreign corporation that owns of CandyCo's stock, and $ of interest to a US corporation. Which of the following statements is true?
a CandyCo is subject to withholding on the $ of interest paid to the foreign corporation owning of the stock because it does not qualify for the portfolio interest exception.
b CandyCo is subject to withholding on the $ of interest to an unrelated foreign corporation on debt that is unassignable because it does not qualify for the portfolio interest exception.
c CandyCo is subject to withholding on the $ of interest paid to a US Corporation because it is FDAP income.
d None of the above are true.
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