Louis, a French citizen, wants to loan money to a related US entity that will be...

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Accounting

Louis, a French citizen, wants to loan money to a related USentity that will be purchasing real estate in Boca. If he sets up aFrench company, then the interest income will be taxed at a highrate. He hears that Switzerland taxes interest at a very low rate.So, he sets up a Swiss company which in turn loans the money to theBoca entity.
What is the withholding rate on interest and dividends under theUS-Swiss treaty? What's the rate under the US-France income taxtreaty?
Can Louis take advantage of the US-Swiss treaty?
You may want to take a look at the Treasury Technicalexplanation that can be accessed at the beginning of every articlein the treaty.

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The United States has income tax treaties or conventions with a number of foreign countries under which residents but not always citizens of those countries are taxed at a reduced rate or are exempt from US income taxes on certain income profit or gain from sources within the United States Amounts subject to withholding tax under chapter 3 generally fixed and determinable annual or periodic income may be exempt by reason of a treaty or subject to a reduced rate of tax These treaty tables provide a summary of many types of income that may be exempt or subject to a reduced rate of tax For more details on the whether a tax treaty between the United States and a particular country offers a reduced rate of or possibly a complete exemption from US income tax for residents of that particular country refer to Publication 901 US Tax Treaties For more details for withholding agents who pay income to foreign persons including nonresident aliens foreign corporations foreign partnerships foreign trusts foreign estates foreign governments and international organizations refer to Publication 515 Withholding of Tax on Nonresident Aliens and Foreign Entities Note The first See Answer

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