I think you're referring to the same setup as rprasad was talking about in his comment (http://news.ycombinator.com/item?id=3055493 http://news.ycombinator.com/

I think you're referring to the same setup as rprasad was talking about in his comment (http://news.ycombinator.com/item?id=3055493 http://news.ycombinator.com/item?id=3055493). (If I'm correct) When a US company pays dividend to it's non US parent company, the US charges a withholding tax of 30%. This can be less if there's a tax treaty between the two countries.