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USAco, a domestic corporation, is a wholly-owned subsidiary of FORco, a foreign corporation. During the current year, USAco distributes a dividend of $100,000 to FORco

USAco, a domestic corporation, is a wholly-owned subsidiary of FORco, a foreign corporation. During the current year, USAco distributes a dividend of $100,000 to FORco and makes an interest payment of $100,000 to FORco. Under the Model Treaty, USAco must withhold total U.S. taxes of:

$60,000.

$5,000.

$10,000.

$35,000

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