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61. Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50-percent-owned joint
61. Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50-percent-owned joint venture, CanCo. CanCo is treated as a corporation for U.S. and Canadian tax purposes. An unrelated Canadian investor owns the remaining 50 percent. Windmill conducts its operations in Ireland through a wholly owned subsidiary, IrishCo. IrishCo is a controlled foreign corporation for U.S. tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid entity, KiwiCo. KiwiCo is treated as a branch for U.S. tax purposes and a corporation for Australian tax purposes. Windmill also owns a 5 percent interest in a Dutch corporation, TulipCo. During 2022, Windmill reported the following foreign source income from its international operations and investments. CanCo IrishCo KiwiCo TulipCo Dividend Income Amount $45,000 Withholding tax 2,250 $28,000 1,400 $20,000 3,000 Interest Income Amount 30,000 Withholding tax 0 Branch Income Taxable income AUS Income taxes $93,000 31,000 13-42 Note: CanCo and KiwiCo derive all of their earnings from active business operations. a) Classify the income received by Windmill into the appropriate FTC baskets. b) Windmill has $1,250,000 of U.S. source gross income. Windmill also incurred SG&A of $300,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $200,000. Compute the FTC limitation for each basket of foreign source income.
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