International Tax IssuesAnswered

What is the branch profits tax under IRC 884 and how does it apply to foreign corporations?

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hans_3bc4new member
July 25, 2019 1,456 views 1 answer
branch profits taxIRC 884foreign corporationU.S. branchdividend equivalenttax treaty

I'm a foreign corporation doing business in the U.S. through a branch (not a subsidiary). My U.S. tax advisor mentioned something called the 'branch profits tax' in addition to regular corporate income tax. What is it, why does it exist, and how is it calculated? Can a tax treaty reduce or eliminate it?

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