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?

Answer rating: 100% (QA)

No the 18000 of branch interest paid to Matthews would not be co... View the full answer