Question
ABC Manufacturing, Inc. a U.S. corporation owns 100% of the stock of FC Inc., which is incorporated under the laws of Country Y. For the
ABC Manufacturing, Inc. a U.S. corporation owns 100% of the stock of FC Inc., which is incorporated under the laws of Country Y. For the tax year 2018, FC Inc., had income of $3,000,000 and paid foreign taxes of $1,000,000. All of the income earned by FC Inc., in Country Y is deemed to be Subpart F Income. ABC Manufacturings had $9,000,000 in U.S. earnings in 2018 in addition to FC Incs income. Assuming a 21% U.S. tax rate compute the following a. The section 960 indirect credit. b. The section 78 Gross-up. c. The section 904 Limitation d. Carryback or carryover amounts.
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