In 1995, Jenson Investments, a Delaware corporation with a 35 percent federal tax rate, formed Bestmark, a wholly owned German subsidiary. Bestmark conducts several profitable businesses in Europe and pays the 45 percent German corporate income tax. Best-mark has never paid a dividend to its U.S. parent and has accumulated $8.2 million after-tax earnings. Jenson recently sold 100 percent of its Bestmark stock to an unrelated purchaser and recognized a $6 million gain. Compute Jenson’s U.S. tax on this gain.