A US corporation has a 100% owned foreign corporation subsidiary in Switzerland. The US Corporation has US source taxable income in the current year of $1,200,000, and authorizes a dividend of $200,000 from its Swiss subsidiary. The Swiss corporation reports the following:

Swiss source net income $ 800,000

Swiss income tax (160,000)

Net earnings and profits $ 640,000

Assume the US Federal income tax on worldwide income is $420,000 and the Swiss withholding tax is 10%.

Compute the corporations foreign tax credit after limitation, for the current year and any foreign tax carryover.