By Jacob Stein Managing Partner, Aliant USA .
Foreign corporations that directly operate a business or own income-producing assets in the United States are subject to a 30% branch profits tax (BPT). For more foreign corporate investors in the U.S., this has led to structuring their U.S. investments through a U.S. corporate subsidiary, resulting in two layers of tax. This article will examine how a Chinese corporation can mitigate U.S. double taxation on their U.S. investments through the favorable application of an income tax treaty.