What will the IRS auditor argue

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Question - USAco is the wholly-owned U.S. subsidiary of FORCo, a foreign corporation. USAco's income statement in millions of dollars, appears as follows:

Income Statement

Gross Profit 400

Administrative Expenses 300

Interest Expense 100

The interest expense of $100 is on a long-term note payable from USAco to FORCo, which is entitled to the benefits of a treaty that exempts interest from withholding tax.

Required - What will the IRS auditor argue when they encounter this taxpayer's facts and circumstances?

Reference no: EM133029356

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