I'll give you a concrete example - if you buy a piece of real property from a foreigner, theoretically you're supposed to withhold 10% of the purchase price and mail it to the IRS as a down payment on the capital gains tax for them. But the minimum tax on such a capital gain is 26%, so obviously the withholding accounts for less than half of the tax due in many cases. QED.
Maybe. The 10% is of the entire purchase price. The 26% is only the capital gain. Gain could be zero or there could be a loss. I thought your original $1,320,828,000 sounded low, but at least you had data. Too many on this thread and others post what they "feel", not what they can prove.