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3. Egor, a United States citizen is engaged in numerous, diverse operations and pays U.S. income tax at a rate of 37%. Egor owns MY

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3. Egor, a United States citizen is engaged in numerous, diverse operations and pays U.S. income tax at a rate of 37%. Egor owns MY LLC, a disregarded entity for U.S. tax purposes. MY LLC manufactures the ubiquitous product, widgets. U.S. sales result in $100,000 of taxable U.S.-source income. Egor projects that he could earn approximately $100,000 of net income in the United Kingdom (the U.K.), where the corporate income tax rate is 20%. To further limit his liability (widgets being a very dangerous product); Egor's MY LLC forms a private limited company in the United Kingdom. The private limited company in the U.K. is not a "per se" entity and therefore, Egor (via the MY LLC) would consider checking-the-box to treat the private limited company in the UK as a disregarded entity. Assume both that the withholding tax rate on any dividends from a U.K. private limited company to the United States is 15% and that the title on all widget sales passes in the UK. a If the UK private limited company is "checked," what is Egor's foreign tax credit position in Year 1 if an $80,000 dividend is distributed for UK tax purposes? b. If the UK private limited company is "checked," what is Egor's foreign tax credit position in Year 1 if a dividend is not distributed for UK tax purposes? c. What is Egor's foreign tax credit position in Year 1 if the UK. private limited company is not "checked" as a disregarded entity and pays a dividend of $80,000 to the MY LLC? d. What is Egor's foreign tax credit position in Year 1 if the U.K private limited company is not "checked" as a disregarded entity and does not pay a dividend

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