Branch Profit Tax for Foreign Company

[Tomer O.]

Hi everyone,

Trying to understand the regulations around branch profit tax.

When making an investment via a Foreign Company in a US investment (Syndication/Real Estate Fund/Private Placement).
I understand BPT is owed on all distributions as well as all profit share when existing the position.
I'm trying to understand if that is the case even if the capital stays in the US. For example, in a US bank account (owned by the Foreign Company), or if the profits are then invested in other US investment?

Regards,

Tomer