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 PA DoR RCT 121C Form 2022-2025

Rct 121c Tax 2022-2025 Form

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in Revenue ruling 71141 a US partnership owned 40% of a foreign corporation the US partnership was owned by two corporate Partners the foreign corporation paid a dividend up to the US partnership and a withholding tax was imposed by country y on the dividend the dividend withholding tax was paid by the partnership and therefore was ACC creditable tax under Section 901 the 901 credit flows up to the partners under the normal partnership rules the ruling made clear that the corporate Partners each met the 10% ownership requirement of section 902 each partner owned 50% of the partnership and the partnership owned 40% of the foreign corporation therefore each partner indirectly owned 20% of the foreign corporation thereby exceeding the 10% required under Section 902 each corporate partner was allowed to claim a deemed paid credit under section 902

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