Branch Profits Tax Estimator

If a foreign corporation engages in a U.S. trade or business directly (without a U.S. Blocker C-Corp), it is subject to the standard corporate tax plus a 30% Branch Profits Tax (BPT) on its 'dividend equivalent amount'.

Increases in U.S. net equity reduce the dividend equivalent amount.

Why Blockers Matter

The BPT is intended to replicate the second level of tax that would apply if the foreign corp had operated through a U.S. subsidiary that paid dividends. Treaties can reduce the 30% rate, but this illustrates why direct operation by a foreign entity is rarely optimal.