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BlueCo, a domestic corporation, incorporates GreenCo, a new wholly owned entity in Germany. Under both German and U.S. legal principles, this entity is a corporation. BlueCo faces a 35% U.S. tax rate.

GreenCo earns $1,500,000 in net profits from its German activities and makes no dividend distributions to BlueCo. How much U.S. tax will BlueCo pay for the current year as a result of GreenCos earnings, assuming no deemed dividend under Subpart F? Ignore and FTC implications.