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Entity Country Percent Owned Activity Income before Tax ($ millions) Income Tax Rate Dividend Withholding Tax Rate Net Amount Received by Parent ($ millions) USIC

Entity Country Percent Owned Activity Income before Tax ($ millions) Income Tax Rate Dividend Withholding Tax Rate Net Amount Received by Parent ($ millions)
USIC USA - Manufacturing $10.00 35% - -
A Argentina 100% Manufacturing $1.00 35% 0% $0.20
B Brazil 100% Manufacturing $2.00 34% 0% $2.50
C Canada 100% Manufacturing $3.00 26% 5% $1.00
D Hong Kong 100% Investment $2.00 16.50% 0% $1.50
E Liechtenstein 100% Distribution $3.00 10% 4% $ -
F Japan 51% Manufacturing $2.00 38% 5% $0.50
G New Zealand 60% Banking $4.00 28% 5% $1.00
Additional Information
1 USIC has $10 million income before tax is derived from the production and sale of products in the United States
2 Each entity is legally incorporated in its host country other than Entity A, which is registered with the Argentinian government as a branch
3 Entities A, B, C, and F produce and market products in their home countries
4 Entity D makes passive investments in stocks and bonds in the Hong Kong financial markets Income is derived solely from dividends and interest
5 Entity E markets good purchased from (manufactured by) USIC Of Es sales, made in Liechtenstein
6 Entity G operates in the chemical industry in New Zealand
Required:
Determine the following:
a The amount of U.S. taxable income for each Entity A-G
b The foreign tax credit allowed in the United States, first by basket and then in total
c The net U.S. tax liability
d Any excess foreign tax credits (identify by basket)

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