Form 8855 Rev March Gpo

Instructions and help about Form 8855 Rev March Gpo

[Music] in Revenue ruling 92-85 situation 1 a foreign parent Corporation owned 100% of a US domestic Corporation DX the foreign parent also owned 100% of a foreign corporation FX and FX in turn owned 100% of foreign corporation FY in the ruling DX paid $200 for the shares of FY so FX received $200 $ from DX or the shares of FY this type of a cross-chain sale of a corporation is known as a section 304 transaction although the mechanics of a section 304 transaction are a bit complex the transaction is generally treated as a dividend out of the acquiring entities earnings and profits and then as a dividend out of the target entity earnings and profits in this example the acquiring entity DX had earnings and profits of 90 and the target entity FY had earnings and profits of 110 thus the transaction was treated as a dividend of 90 out of DX to FX and then as a dividend of 110 out of FY to FX the US generally imposes a 30% dividend withholding tax on dividends paid by us corporations to fore