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03.01.2010 U.S. Subsidiary’s Guaranty Payments to Foreign Parent are Not U.S.-Sourced Income Subject to Withholding Tax
03. 2010
In Container Corp. v. Commissioner, the United States Tax Court examined the source of fees that a U.S. subsidiary corporation paid to its foreign parent corporation in return for the foreign parent’s guarantee of the U.S. subsidiary’s debts.

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