ABC Corporation is a US corporation that made a dividend payment to its parent, a foreign partnership.
Question:
ABC Corporation is a US corporation that made a dividend payment to its parent, a foreign partnership. The foreign partnership has two equal owners. A Corp., the first corporate owner, is a resident of a country with a tax treaty with the United States that is identical to the US Model Treaty. B, the second individual owner, is a resident of a country with no tax treaty with the United States.
Please assume that the United States recognizes the foreign partnership as a partnership, and not as a corporation.
If ABC pays a dividend payment to the foreign partnership of $100,000, how much cash will A Corp receive if the dividend is distributed by the partnership to its owners upon receipt of the cash?
Smith and Roberson Business Law
ISBN: 978-0538473637
15th Edition
Authors: Richard A. Mann, Barry S. Roberts