• Isinterestoneachofthedebtobligationsdescribedbelowsubjecttotaxunder87l(a)(l)or88l(a)?Isitsubjecttowithholdingunder1441or1442?WouldthetaxbeaffectedbyatreatybetweentheUnitedStatesandtherelevantforeigncountryinaformidenticaltotheU.S.Model?
  • A Canadian corporation holds a note issued to it by its wholly owned subsidiary, a corporation organized under the laws of Michigan.
  • A citizen and resident of Nigeria holds a certificate of deposit issued by a New York bank.
  • A citizen and resident of Bolivia owns a bond issued by General Electric Co. (GE), a New York corporation, but owns no GE stock.
  • A citizen and resident of Saudi Arabia holds a subordinated debenture issued by a Florida corporation and also owns percent of the corporation's stock. The debenture is guaranteed by the corporation's parent, a Panamanian corporation. The Florida corporation defaults on an interest payment and the Panamanian corporation pays as guarantor.
  • A partnership organized under the laws of Canada purchases property from a citizen and resident of Argentina under an agreement requiring the purchase price to be paid in 10 annual installments, without interest. The partnership has a trade or business in the United States, but this business produces only a small portion of the partnership's income, and the property purchased from the Argentinian seller is acquired for use in the partnership's business in Argentina. The Argentinian seller owns a 15 percent interest in the partnership as limited partner.
  • A New York branch of a Swiss bank makes a loan to a Delaware corporation for use in its U.S. businesses.
  • A Cayman Islands bank makes a loan to a Swiss branch of a Delaware corporation.
  • A Cayman Islands bank receives interest-bearing deposits from U.S. citizens.
  • A Swiss branch of a New York bank receives interest-bearing deposits from Swiss residents.
  • A U.S. citizen residing in Peru owes money to an acquaintance in Peru and has given an interest-bearing note to evidence the obligation to repay.