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i am the sole shareholder of a delaware corporation that has

no activity at all in...
i am the sole shareholder of a delaware corporation that has no activity at all in the USA and i have decided to create a branch with the same name in portugal were i have a permanent establishement and are paying my taxes Do i need to declare for tax purposes as well in usa in income of the portuguese branch in usa or am i exempt to avoid double taxation ?
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Answered in 36 minutes by:
6/23/2013
Lev
Lev, Tax Advisor
Category: Tax
Satisfied Customers: 30,722
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LEV :

Hi and welcome to Just Answer!
Because that is a corporation registered in the US - it is required to file a federal annual tax return regardless of not having any activity. You need to file the form 1120 U.S. Corporation Income Tax Return.
All worldwide income is reported - included income from a foreign subsidiary. If the same income is subject of income tax in a foreign country - the corporation may claim a credit for foreign taxes - thus - effectively will avoid double taxation.

LEV :

See for reference
http://www.irs.gov/file_source/pub/irs-pdf/f1118.pdf
http://www.irs.gov/file_source/pub/irs-pdf/i1118.pdf
www.irs.gov/pub/irs-pdf/f1120.pdf‎
www.irs.gov/pub/irs-pdf/i1120.pdf‎

Lev
Lev, Tax Advisor
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