ForeignCorp is a Country Y corporation that is not a bank; and is engaged in a USTB.
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Question:
ForeignCorp is a Country Y corporation that is not a bank; and is engaged in a USTB. The interest expense that is allocated to the ECI of ForeignCorps USTB totals $ in as determined under Reg. Of that amount, $ is branch interest, which is paid by the US branch to Matthews, an unrelated Country Y nonresident alien. No tax treaty applies. Is the $ of branch interest paid to Matthews portfolio income?
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