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ABC, Inc., a domestic corporation, owns 100% of HighTax, a foreign corporation. High Tax has $50,000,000 of undistributed E & P, all of which is
ABC, Inc., a domestic corporation, owns 100% of HighTax, a foreign corporation. High Tax has $50,000,000 of undistributed E & P, all of which is attributable to general limitation income, and $30,000,000 of foreign income taxes paid. HighTax distributes a $5,000,000 dividend to ABC. The dividend, which is subject to a 5% foreign withholding tax, is ABC's only item of income during the year. The U.S. tax rate is 35%. a. ABC's deemed-paid taxes on the dividends are X, and the foreign withholding taxes actually paid are b. The foreign tax credit claimed is $ X. C. ABC now has excess foreign tax credits of $ X is in general limitation basket. Feedback Check My Work If a U.S. corporation operates in a foreign country through a branch, the direct credit is available for foreign taxes paid
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