Bismarck Corporation has a precredit U.S. tax of $210,000 on $1,000,000 of taxable income in 2021. Bismarck has $200,000 of foreign source taxable income characterized as foreign branch income and $50,000 of foreign source taxable income characterized as passive category income. Bismarck paid $80,000 of foreign income taxes on the foreign branch income and $10,000 of foreign income taxes on the passive category income. What amount of foreign tax credit (FTC) can Bismarck use on its 2021 U.S. tax return and what is the amount of the carryforward, if any? $90,000 FTC with $0 carryforward $52,000 FTC with $0 carryforward $16,500 FTC with $73,500 carryforward $52,000 FTC with $38,000 carryforward Windmill Corporation, a Dutch corporation, is owned by the following unrelated persons: 50 percent by a U.S. corporation, 5 percent by a U.S. individual, and 45 percent by a Swiss corporation. During the year, Windmill earned $2,000,000 of subpart F income. Which of the following statements is true about the application of subpart F to the income earned by Windmill? Windmill is a CFC and the U.S. corporation, U.S. individual, and Swiss corporation will have a deemed dividend of $1,500,000, $100,000, and $900,000, respectively. Windmill is not a CFC and none of the shareholders will have a deemed dividend under subpart F. Windmill is a CFC and only the U.S. corporation will have a deemed dividend of $1,000,000. Windmill is a CFC and the U.S. corporation and U.S. individual will have a deemed dividend of $1,000,000 and $100,000, respectively. Under which of the following scenarios could Charles, a citizen of England, be eligible to claim the "closer connection" exception to the substantial presence test in 2021? Charles spent 183 days in the United States in 2021 and has his tax home in the United States. Charles spent 182 days in the United States in 2021 and has his tax home in England. Charles spent 183 days in the United States in 2021 and has his tax home in England. Charles spent 182 days in the United States in 2021 and has his tax home in the United States