Question
USP, a US corporation, owns 100% of German Inc., a German corporation and 5% of UK Inc, a UK corporation. German distributes a $100,000 dividend
USP, a US corporation, owns 100% of German Inc., a German corporation and 5% of UK Inc, a UK corporation.
German distributes a $100,000 dividend to USP and UK distributes a $50,000 dividend to USP.
How much withholding tax will USP be subject to assuming they are eligible for treaty benefits and the US model treaty is the applicable treaty?
Same facts as above except USP hires independent agents in Germany to perform services and earns $10,000 pre-tax income from those services. The German corporate tax rate is 30%. How much tax will USP have to pay to Germany?
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