Allen Blay owns 100% of the stock in AB Corporation, organized ten years ago in California. AB operates a foreign branch in Country A. In the current year, AB reports $500,000 of taxable income from U.S. activities. The branch reports a 400,000 pirog loss, which translates into a $60,000 (U.S.) loss. Neither the branch nor the U.S. corporation paid Country A income taxes in the current year?