It provided that dividends, interest, rents and royalties paid by one foreign subsidiary out of its business profits to a related foreign subsidiary are not subject to current U.S. tax (IRC section 954(c)(6)).
The cash tender offer commenced on August 23, 2010 by Dell, through a wholly-owned subsidiary, is for all outstanding shares of 3PAR common stock, without interest, and subject to reduction for any federal back-up withholding or other taxes.