What is the branch profits tax? Explain the Congressional intent behind its enactment.

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The branch profits tax is imposed on the U.S. branch of a foreign corporation. It is equivalent to the tax that would be imposed on distributions made by the U.S. subsidiary of a foreign parent corporation. The branch tax is levied on either the branch's dividend-equivalent amount or its allocable interest. The dividend-equivalent amount tax base equals the foreign corporation's E&P for the tax year that is effectively connected with the conduct of its U.S. trade or business increased by earnings remitted by the branch to the foreign corporation and decreased by earnings reinvested in assets related to the branch's conduct of a U.S. trade of business. The allocable interest portion of the tax provides that certain interest paid by a U.S. trade or business of a foreign corporation is treated as U.S.-source interest and as such is possibly subject to withholding as if paid by a U.S. corporation. The branch profits tax is imposed in an attempt to equate the tax treatment of U.S. branch activities and U.S. subsidiary corporations owned and/or operated by foreign parent corporations. Were the branch profits tax not in place, no tax would be imposed on remittances made by a branch activity to its foreign parent corporation. A 30% rate (or a lower rate specified in a tax treaty), however, would be imposed on remittances made by a U.S. subsidiary corporation to its foreign parent corporation. The branch profits tax attempts to reduce these differences.

Business

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Business

The ___________ process would be used to establish and develop relationships with suppliers.

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Business

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What will be an ideal response?

Business

Describe the activities that occur at each stage of a project

What will be an ideal response?

Business