From what I understand (which might be wrong since I don't live in the US) the US retains 30% of all dividends (to which we in Norway may demand a writeof on our own taxes I believe). For cash dividends it is easy as you point out, but they can't retain 30% of the TRW-shares - hence SIAF has to provide those 30% in cash.
They are working on other options to potentially reduce or completely eliminate the tax liability as well
Is there any other way than 1) do the dividends from a non-US company (i.e CA or TRW), or 2) make SIAF a non-US company?