AustinNZ,
Australian would get a tax credit for dividends from USA earnings (20%? company tax rate, but not the Federal Government take from GOM production an additional 12.5%?) because Australia has a Tax Treaty with the USA.
Australia-Brazil doesn't currently have a tax treaty with Brazil. So currently no foreign tax credit from Brazil earnings.
However, Australia-Brazil are currently or planning to negotiate a treaty. This will likely take a few years to get in place. So plan for around 2027?
It will only be at the Brazil corporate tax rate (less than the 34% that you quote?).
KAR may be able to assert that a dividend is paid from USA profits which would be eligible for the foreign tax credit offset (not refundable, so not as good as franking credits for many including me).
AustinNZ,Australian would get a tax credit for dividends from...
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