Making Member's Mark Products for Sam's Club: Does a Chinese Factory Owe U.S. Tax?
A Chinese factory producing at home and selling FOB into Walmart's buying system, with no U.S. permanent establishment, generally owes no U.S. income tax and gives a W-8BEN-E. A U.S. subsidiary delivering in the U.S. pays 21% federal tax, files Form 5472 and needs transfer pricing. U.S. staff or stock can change the answer.
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