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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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