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Yes, they have to file, but it does matter:

> In general, under Section 883 of the Internal Revenue Code, certain non-U.S. corporations (such as our North American cruise ship businesses) are not subject to U.S. federal income tax or branch profits tax on U.S. source income derived from, or incidental to, the international operation of a ship or ships

From https://www.carnivalcorp.com/financial-information/annual-re...



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