Sombrero Corporation, a U.S. corporation, operates through a branch in Espania. Management projects that the company's pretax income in the next taxable year will be $100,000, $80,000 from U.S. operations and $20,000 from the branch. Espania taxes corporate income at a rate of 45%. The U.S. corporate tax rate is 35%.
a. If management's projections are accurate, what will be Sombrero's excess foreign tax credit in the next taxable year? Assume all of the income is general category income.
b. Management plans to establish a second branch in Italia. Italia taxes corporate income at a rate of 30%. What amount of income will the branch in Italia have to generate to eliminate the excess credit generated by the branch in Espania?