An USA corporation own by foregin 2 shares holders 50% 50% one wants the liquidation of the company so the other will keep the company in the liquidation Capital this share holder has to pay Taxin USA or in his origin country
If the US corp has two foreign shareholders and one shareholder sells his/her shares to the other shareholder and there is a gain/loss, no tax is payable in the US by the foreign shareholder.
The US does not tax foreign shareholders capital gains of US securities. It does however require withholding on dividends and certain interest payments to non U.S. persons.
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