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For non-US C Corporations in the post-2017 world what are two common planning structures to maximize usage of foreign tax credits and/or reduce the overall

For non-US C Corporations in the post-2017 world what are two common planning structures to maximize usage of foreign tax credits and/or reduce the overall U.S. tax. Assume in situation 1 that the foreign rate is low (for example 5%) and the other, the foreign rate is higher (for example 30%). Further, assume that there are no withholding taxes and that the US investor wants all earnings repatriated as earned (Don't want to do deferral).

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