Question
Chapeau Company, a U.S. corporation, operates through a branch in Champagnia. The source rules used by Champagnia are identical to those used by the United
Chapeau Company, a U.S. corporation, operates through a branch in Champagnia. The source rules used by Champagnia are identical to those used by the United States. For 2017, Chapeau has $9,200 of gross income, $5,520 from U.S. sources and $3,680 from sources within Champagnia. The $5,520 of U.S. source income and $3,220 of the foreign source income are attributable to manufacturing activities in Champagnia (general category income). The remaining $460 of foreign source income is passive category interest income. Chapeau had $2,300 of expenses other than taxes, all of which are allocated directly to manufacturing income ($920 of which is apportioned to foreign sources). Chapeau paid $690 of income taxes to Champagnia on its manufacturing income. The interest income was subject to a 10 percent withholding tax of $46. Assume the U.S. tax rate is 35 percent. Compute Chapeau's allowable foreign tax credit for 2017.
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