Question
USAco, a domestic corporation, is the wholly-owned U.S. subsidiary of FORco, a foreign corporation, created in Country F. The U.S.-Country F tax treaty exempts interest
USAco, a domestic corporation, is the wholly-owned U.S. subsidiary of FORco, a foreign corporation, created in Country F. The U.S.-Country F tax treaty exempts interest payments from withholding taxes. USAcos financial statements for December 31 of the relevant tax year appear as follows:
BALANCE SHEET
Assets Liabilities & Owners Equity
Cash $300 Notes Payable $1200
Receivables $1500 Owners Equity $600
INCOME STATEMENT
Gross Income $1500
Administrative Expenses $1250
Interest Expense $300
The interest expense of $300 arises from a note payable from USAco to FORco. What is the maximum amount of interest USAco may deduct on its U.S. return? What can it do with any interest expense that is not deductible for that tax year?
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