Question
Gouda, S.A., a Belgium corporation, received the following sources of income and incurred the following related expenses during 2021: a. $10,000 interest income from a
Gouda, S.A., a Belgium corporation, received the following sources of income and incurred the following related expenses during 2021:
a. $10,000 interest income from a loan to its 100 percent owned Dutch subsidiary; related expenses of $1,500.
b. $8,000 interest income from deposits with a U.S. bank; related expenses of $500.
c. $20,000 dividend income from its 100 percent owned U.S. subsidiary; related expenses of $5,000.
d. $30,000 royalty income from its Irish subsidiary for use of a trademark outside the United States; related expenses of $12,000.
e. $40,000 rent income from its Canadian subsidiary for use of a warehouse located in Wisconsin; related expenses of $35,000.
f. $15,000 gross proceeds from the sale of stock in its 40 percent owned New Zealand joint venture; adjusted basis in stock of $5,000. Stock was held for more than 1 year. Title passed in New Zealand.
For each of the above amounts, indicate whether or not it is subject to U.S. withholding and why (or why not). If it is subject to withholding, determine the amount of withholding, and indicate who is responsible for the U.S. withholding.
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