Page 14 - International Taxation IRS Training Guides
P. 14
Business Outbound Illustration
U.S.
Parent
Foreign Foreign U.S. U.S.
Sub
Branch Foreign Corp Branch
P-ship
•Current foreign 12.5% Current U.S.
tax 35% tax
•U.S. tax deferred until
•Current foreign 12.5% distribution (except for
tax
•Current U.S. 35% tax anti-deferral rules)
for foreign tax)
(less FTC
12
