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King Washington Form Instructions 1120-S: What You Should Know
United States Government program (i.e. military or veterans programs, etc.) Income tax withholding on an amount equal to at least 10 percent of the corporation's gross receipts arising in the foreign country or other foreign territory that the corporation controls. 5. Dividends on an amount equal to at least 10 percent of the corporation's capital stock. 6. Dividends from non-owned subsidiary corporations, including interest paid on dividends paid from such subsidiary. 7. Interest on the following amounts (from section 1221(a) of the Income Tax Act): a. Nonqualified deferred recognition (Form 2555); b. Income attributable to any source by reason of tax treaties, arrangements, or conventions; c. Income derived by a tax haven entity, or from the activities of a tax haven entity, through investment or other transactions not subject to the 10 percent foreign withholding requirement. 8. Interest on the following amounts, in addition to any other tax and withholding: a. Excessive indebtedness (Form 2555-A and/or Form 2555-D); b. Investment income on which the foreign withholding tax applies; c. Income to which section 1221 applies (see Schedule 1a for Schedule 1-A and Schedule 1-B); 9. Interest on amounts paid during the tax year pursuant to section 561, 646(a), 697, or 699; and 10. Any other specified amounts determined by the Secretary. The foreign withholding tax does not apply to amounts transferred by a U.S. corporation to a foreign corporation, except as prescribed under section 1221(a), and amounts transferred by a U.S. corporation for the benefit of its foreign parent corporation. However, such transfer to a foreign corporation for the benefit of its foreign parent is treated as a transfer of a foreign corporation's income under section 1241. Any amount paid pursuant to section 561 or 1241 to foreign corporations is treated as a payment of income tax. If any of these specified amounts exceed 10 million in a taxable year, the corporation must pay U.S. tax on that excess over the foreign tax credit allowed pursuant to §1.9100-4(a)(1), (a)(2), or (d). The Secretary may exclude from gross income any amount paid to a foreign tax-exempt organization. Any amount paid to or from a U.S. corporation for the benefit of a foreign partnership is treated as paid by the U.S.
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