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SEC. 1442. WITHHOLDING OF TAX ON FOREIGN CORPORATIONS.
(a) General Rule.--In the case of foreign
corporations subject to taxation under this subtitle,
there shall be deducted and withheld at the source in
the same manner and on the same items of income as is
provided in section 1441 a tax equal to 30 percent
thereof. * * *
Respondent determined that petitioners were liable for
withholding tax on the deficiencies related to:
(a) Interest that MDT and MSI paid to MABV and MTBV,
respectively;
(b) franchise fees that MANV paid to Manver in the fiscal
year ended November 30, 1987;
(c) amounts that MDT and MSI paid to Manver in March 1988;
(d) amounts that MANV, MSI, and MDT paid to Eurotor as
management and consulting fees;
(e) guarantee fees that MDT and MSI paid to Dapy and
Roundabout in connection with the commercial paper transactions;
(f) interest that MDT and MSI paid to the commercial paper
holders; and
(g) fees that MANV paid to Santandreu and Segui in the
fiscal year ended November 30, 1987.
The aggregate amounts for MSI and MDT are approximately as
follows:
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