IRS Issues Private Letter Ruling Exempting Foreign Corporation from Branch Profits Tax Under U.S.-Country A Treaty

The IRS issued a private letter ruling on I.R.C. §884 confirming that no branch profits tax will be imposed on a Country A corporation’s dividend equivalent amount for U.S. net equity attributable to its wholly owned U.S. limited liability companies, as the taxpayer qualifies for exemption under Article 11(3)(b) of the U.S.-Country A Treaty as a subsidiary of a publicly traded company. [PLR 202607002]

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