During $2020,$ Trike, Inc., a domestic C$-$Corporation, receives a $$10,000,000$ dividend from its wholly$-$owned Spanish subsidiary, Trike SA$,$ which is composed entirely of foreign$-$source income generated from business activities in Spain. Trike, Inc. formed Trike SA in early $2018,$ and, since its inception, none of Trike SA$$s income has been subject to the U$.$S$.$ anti$-$deferral rules. Assume that the U$.$S$.$ corporate tax flat rate is $21\%$ and the dividend incurs a Spanish withholding tax of $5\%.$ As a result of the dividend, what is the Spanish tax due and the U$.$S$.$ tax due?

Trike SA

Post$-2017$ undistributed E&P $$90,000,000$

Post$-2017$ Spanish income taxes $$36,000,000$