How does IRC 1442 withholding on foreign corporations differ from IRC 1441 withholding on individuals?
I have a holding company in the Netherlands that owns a U.S. LLC which elected corporate status. My U.S. accountant keeps mentioning both IRC 1441 and IRC 1442 — one for individuals and one for corporations. Since my Dutch company receives dividends from the U.S. entity, which withholding provision applies? And does the U.S.-Netherlands treaty help reduce the rate?
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