Aqua, a South Carolina corporation, is a 20 percent partner in a Swiss partnership. This year, Aqua earned $2 million U.S. source income and $190,000 foreign source income. It paid no foreign income tax. The Swiss partnership earned $1.73 million foreign source income and paid $460,000 income tax to Switzerland, France, and Austria. Compute Aqua’s U.S. tax, assuming the foreign source income does not qualify as DII.