Sure I can address tax issues here. I am assuming from your post a domestic Ccorporation u201cDCu201d formed in a particular state in the United States owns 100of the shares of foreign corporation u201cFCu201d which operates from Argentina.And I am assuming the FC has no US offices u2023 the FC is ran from Argentina.If this assumption is not true u2023 and the FC is materially ran from the US theFC reports its taxable income in the US by filing a 1120 F corporate taxreturn and pays tax at a 21 rate Treasury Regulation Section 1.60122g1and Section 11b. As a FC ran from the US has effectively connected incomefor its foreign source income as noted in Section 864c4B. And Treasurytaxes a FC on its effectively connected income from a United States Trade orBusiness Section 882a. And the office in the US creates the United StatesTrade or Business. Though the FC may use the FC taxes paid in Argentina ascredit for taxes due in the US Section 901 subject to limiting restrictionsunder Section 904.Assuming the FC has no US office and only Argentina operations the FC doesnot file a tax return in the US. Here I am assuming the FC has no subpart Fincome from certain activities.A new reporting regime exists for tax years 2023 for a DC owning the shares ofa FC under Section 951A. While this provision has extensive reportingrequirements the DC does not owe any additional tax on the FC operations ifthe FC pays tax at 13.125 tax rate or greater in the home country. SinceArgentina has a 30 plus tax rate additional tax may not apply here thoughreporting requirements do apply at the DC corporate tax level.Under new Section 245A a DC may receive dividends from the FC with no taxcost for 2023 forward.The DC also have important treasury information reporting requirements underSection 6038a for its FC. Failure to complete this documentation fully orfailure to file this Treasury report carries a 10000 minimum penalty. Wefile this information report as part of filing the 1120 DC corporate taxreturn.I have completed the above analysis by summarizing key provisions above. Ifthe situation changes in anyway the tax results may change considerably.www.rst.tax