Page 51 - International Taxation IRS Training Guides

Inbound - Repatriation/Withholding

the foreign MNE
 Once profits are earned in an FCC,

strategically plan to bring the money “home” (out
will
of the U.S.)

 To prevent income earned in the U.S. permanently

escaping U.S. taxation:

• Payments o
f U.S.-source FDAP income including dividends
FCC to foreign person may be subject to withholding tax
by
may be modified by treaty).
(as

• U.S.
branch E&P shifted out of, or amounts of interest
by, U.S. branch of foreign corporation may be
deducted
subject
to branch profits tax or branch level interest tax.

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