Question
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.
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, Harold has $920 of gross income, $552 from U.S. sources and $368 from sources within Champagnia. The $552 of U.S. source income and $322 of the foreign source income are attributable to manufacturing activities in Champagnia (general category income). The remaining $46 of foreign source income is passive category interest income. Harold had $230 of expenses other than taxes, all of which are allocated directly to manufacturing income ($92 of which is apportioned to foreign sources). Harold paid $69 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.
Required:
Compute Harold' s allowable foreign tax credit in 2017.
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