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Windmill Corporation manufactures products in its plants in lowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a $50$ percent$-$owned.joint venture, CanCo. CanCo is treated as a corporation for U$.$S$.$ and Canadian tax purposes. An unrelated Canadian investor owns the remaining $50$ percent. Windmill conducts its operations in Ireland through a wholly owned subsidiary, IrishCo. IrishCo is a controlled foreign corporation for U$.$S$.$ tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid entity, KiwiCo. KiwiCo is treated as a branch for U$.$S$.$ tax purposes and a corporation for Australian tax purposes. Windmill also owns a $5$ percent interest in a Dutch corporation, TulipCo.

During $2023,$ Windmill reported the following foreign source income from its international operations and investments.

$\backslash$table$[[,$CanCo,IrishCo,KiwiCo,TulipCo$],[$Dividend income,$$51,000,$$$42,000,,],[$Amount$,2,550,2,100,,],[$Withholding tax,,,,$],[$Interest income,$$35,000,,,],[$Amount$,0,0,,],[$Withholding tax,,,,$],[$Branch income,,,$$100,600,],[$Taxable income,,,$$33,500,],[$AUS income taxes,,,,$]]$

Note: CanCo and KiwiCo derive all of their earnings from active business operations.

Required:

a$.$ Classify the income received by Windmill into the appropriate FTC baskets.

b$.$ Windmill has $$1,260,000$ of U$.$S$.$ source gross income. Windmill also incurred SG&A of $$310,000$ that is apportioned between U$.$S$.$ and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $$233,500.$ Compute the FTC limitation for each basket of foreign source income.

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