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- - 1. Galaxy Corp, a US Corp, manufactures optical equipment in its San Diego plant. Galaxy conducts an extensive R&D operation in San
- - 1. Galaxy Corp, a US Corp, manufactures optical equipment in its San Diego plant. Galaxy conducts an extensive R&D operation in San Diego resulting in many patents in the US and most industrialized countries. Galaxy granted on 1/1/X1 a nonexclusive license covering foreign patents on one of its important inventions to an unrelated company organized in the Czech Republic. On 1/1/X1, Galaxy also acquired interest-bearing debt obligations of foreign borrowers. These debt obligations produce yearly interest income of $300,000 on which Galaxy pays $45,000 of foreign income taxes. In addition, on 1/1/X1, Galaxy established an export sales branch in Hungary to handle export sales of optical products Galaxy purchases from unrelated manufacturers in the US. All income (or loss) of the branch is sourced in Hungary. Galaxy Year 1 Results: - Galaxy received $300,000 of foreign-source interest income on which it paid $45,000 of foreign income tax Galaxy received royalties from the Czech licensee of $100,000, which are subject to Czech withholding tax of 10% ($10,000) Hungarian sales branch had a loss of $100,000 Galaxy had $700,000 of taxable income from its US operations all sourced in the US Assume that Galaxy's effective US tax rate is 21% and that all years start after 2017. Under $904, how much foreign tax will Galaxy be allowed to credit for year 1?
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