How will the us tax fc on its dividend income from usco

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Question: FC, a Canadian company, bought 20% of a small private US company ("USCO") years back for investment purposes and a few years ago, FC opened a branch in the United States. The branch manufactures luggage for sale throughout the United States. In 2023, USCO pays FC a dividend of $200,000 and FC's US branch generates taxable income of $100,000. Consider the US-Canada Income Tax Treaty and any Protocols thereto (i.e., revisions) for any potential impact as to your answer. How will the US tax FC on its dividend income from USCO?

Reference no: EM133655581

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