Casa Vinicola Zonnin SpA, an Italian corporation, is engaged in the production of wine in Italy. Zonnin maintains a branch in the US which acts as importer and distributor of the wine it manufactures in Italy. The branch in the US is required to hold a large current cash balance for business purposes, but the amount of the cash balance so required varies because of the fluctuating seasonal nature of the branch's business. During 2014 at a time when large cash balances are not required the branch invests the surplus amount in US Treasury bills. Is there withholding on the interest?