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How much withholding tax will USP be subject

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Question - Please read the below and answer the question at the end:

USP, a US corporation, owns 100% of German Inc., a German corporation and 5% of UK Inc, a UK corporation.

German distributes a $100,000 dividend to USP and UK distributes a $50,000 dividend to USP.

How much withholding tax will USP be subject to assuming they are eligible for treaty benefits and the US model treaty is the applicable treaty?

Reference no: EM132608567

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