During 2020, FTrike, a foreign subsidiary, distributes a $10 million dividend to Trikeco, a U.S. C corporation. Assume that the U.S. corporate tax rate is 21% and the dividend incurs a withholding tax of 5%. As a result of the dividend, what is the foreign tax due and the U.S. tax due?

FTrike

Post-2017 undistributed E&P $90 million

Post-2017 foreign income taxes $36 million