1. Discuss the following: Chris, a non resident alien, owns fi ve percent of USAco, a domestic corporation. USAco pays Chris a $1,000 dividend during the current year. Chris also purchases a bond issued by USAco, and receives a $1,000 payment. USAco derives over 90 percent of its gross income from its business operations in Canada. Are there any U.S. withholding requirements with respect to these interest and dividend payments? Discuss the reasoning for your answer.
2. A citizen and resident of Country X hold a certificate of deposit issued by a US State Bank. Is the interest income received by the Country X recipient subject to US tax? And if so, how would it generally be taxed?
3. A US State Bank has a branch in Country X. A Country X resident receives interest income from deposits maintained in accounts at the branch of US State Bank located in Country X. Is the interest income received by the Country X recipient subject to US tax? And if so, how would it generally be taxed?
4. A citizen and resident of Country X owns a bond issued by USCo, a US Corporation. The bond owner also owns 15% of the stock of USCo. Is the interest income from the bond received by the Country X recipient subject to US tax? And if so, how would it generally be taxed?
5. A citizen and resident of Country X owns stock of USCo, as US Corporation. USCo is preparing to issue a dividend to its shareholders. The Country X shareholder has provided no information to USCo other than his Country X address. Will the dividend being distributed to the Country X shareholder be subject to US tax? And if so, how would it generally be taxed?
6. A 1% owner of USCo, a US Corporation, provides a W-9 to USCo. Is withholding required on payment of a dividend from USCo to the shareholder? Why or why not? If so, at what rate (in general terms)?
7. A 1% owner of USCo, a US Corporation, provides a W8-BEN to USCo. Is withholding required on payment of a dividend from USCo to the shareholder? Why or why not? If so, at what rate (in general terms)?