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ForCo, a foreign corporation not engaged in a U.S. trade or business, received a $600,000 dividend from USCo, a domestic corporation. ForCo incurred $45,000 in

ForCo, a foreign corporation not engaged in a U.S. trade or business, received a $600,000 dividend from USCo, a domestic corporation. ForCo incurred $45,000 in expenses related to earning the dividend, All of USCo's income is from U.S. sources. ForCo is not eligible for any treaty benefits.

What is the withholding tax on the dividend paid to ForCo?

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