DomCo, a domestic corporation, is a wholly - owned subsidiary of HKco, a Hong Kong corporation. The
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DomCo, a domestic corporation, is a whollyowned subsidiary of HKco, a Hong Kong corporation. The US does not have a tax treaty with Hong Kong, but both the US and Hong Kong do have a treaty with country F that eliminates all withholding taxes. To avoid the withholding tax, which DomCo must withhold on all interest payments to HKco, it forms AbroadCo, a country F corporation, what will borrow the money from HKco and relend the money to DomCo?
Related Book For
Federal Taxation 2016 Comprehensive
ISBN: 9780134104379
29th Edition
Authors: Thomas R. Pope, Timothy J. Rupert, Kenneth E. Anderson
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