Quality Coffee S.A., is a corporation organized in Mexico. It is not a bank and is not

engaged in a U.S. trade or business.

Major Banco S.A., is a corporation organized in Brazil. It is a bank that conducts all forms of normal banking business, but is not engaged in a U.S. trade or business.

Major Banco made a 10-year loan of $5 million Quality Coffee. Major Banco does not own any equity interest in Quality Coffee. What is the U.S. tax consequence to Major Banco on $200,000 of interest income received from the loan made to Quality Coffee?

a) The $200,000 of interest income is subject to U.S. net income tax

b) The $200,000 of interest income is subject to gross U.S. withholding tax at 30%

c) No U.S. tax because the interest is paid by a non-U.S. corporation

d) No U.S .tax because paying U.S. tax is voluntary