Question
Aqua, Inc., a calendar-year domestic corporation, owns 30% of the stock of Wasser, Inc., a specified foreign corporation. Prior to 2018, Wasser has accumulated earnings
Aqua, Inc., a calendar-year domestic corporation, owns 30% of the stock of Wasser, Inc., a specified foreign corporation. Prior to 2018, Wasser has accumulated earnings and profits of $1,000,000 and a cash position of $200,000. Assume that Wasser paid no foreign tax on these earnings. For tax year ending December 31, 2017, Aqua is treated as receiving a constructive dividend from Wasser of $300,000 ($1,000,00030%), with $60,000 ($200,00030%) of this amount attributable to Wasser's foreign cash position. How much is Aqua's tax liability on the constructive dividend?
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