Branch Profits Tax Concepts – Internal Revenue Service

The branch profits tax provision under IRC 884(a) treats a U.S. branch of a foreign corporation as if it were a U.S. subsidiary of a foreign corporation for purposes of taxing profit repatriations. As such, IRC 884(a) 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 U.S. subsidiary paid out …