I keep hearing about 'branch profits tax' for foreign-owned U.S. corporations — does it apply to a Delaware C-corp owned by an NRA?
I'm a non-resident alien sole shareholder of a Delaware C-corp (formed via Form 8832 election from a single-member LLC). My CPA mentioned 'branch profits tax' under §884. I thought BPT only applied to actual foreign branches of foreign corporations — not to U.S. corporations that happen to have foreign owners. Can someone clear up when §884 actually fires for a structure like mine?
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