Global Definitions Database

Taxation under Internal Revenue Code (IRC) Section 884(a) that treats a US branch of a foreign corporation as if it were a US subsidiary of a foreign corporation for purposes of taxing profit repatriations; puts the earnings and profits of a branch of a foreign corporation deemed remitted to its home office on equal footing with the earnings and profits of a US subsidiary paid out as a dividend to its foreign parent; applies regardless of whether the US trade or business of the foreign corporation is substantial compared to its worldwide operations.