Detailed analysis. Introduction -- Branch profits tax -- Branch interest withholding tax -- Tax on excess interest -- Application of U.S. tax treaties -- Branch reporting requirements -- Working papers.
Summary:
" ... analyzes the branch-related taxes of [section] 884, i.e., the branch profits tax, the branch level interest withholding tax, and the excess interest tax. These taxes may be applicable to a foreign corporation engaged in a trade or business in the United States (in addition to the regular corporate income tax, which is imposed on the taxable income of the foreign corporation effectively connected with its U.S. trade or business).
Published as Tax Management Portfolio 909-3rd, -2013. Published: Washington, D.C., 2005-2007. AVAILABLE ONLINE TO AUTHORIZED DICKINSON USERS; PASSWORD REQUIRED FOR ACCESS.
