Whether a favorable tax treaty exists that reduces the withholding tax rates on dividends, interest, and royalties paid by USSub to FORco, and Whether FORco conducts its U.S. operations as a corporation, a domestic hybrid entity, or a domestic reverse hybrid entity. FORco can model the effect of these factors by computing the worldwide tax rate on USSub's earnings under a variety of assumptions. Case 3: Pays dividend / No tax treaty Now assume that there is not a tax treaty between the United States and country F, such that the U.S.'s statutory withholding rate on dividends of 30% applies. The lack of a favorable treaty withholding rate increases the total tax rate on USSub's repatriated and unrepatriated earnings, computed as follows: U.S. income fax.