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Euro Corporation, a U.S. corporation, operates through a branch in Germany. During 2019 the branch reported taxable income of $1,000,000 and paid German income taxes

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Euro Corporation, a U.S. corporation, operates through a branch in Germany. During 2019 the branch reported taxable income of $1,000,000 and paid German income taxes of $300,000. In addition, Euro received $50,000 of dividends from its 5 percent investment in the stock of Maple Leaf Company, a Canadian corporation. The dividend was subject to a withholding tax of $5,000 Euro reported U.S. taxable income from its manufacturing operations of $950,000. Total taxable income was $2,000,000. Precredit U.S. taxes on the taxable income were $420,000. Included in the computation of Euro's taxable income were "definitely allocable" expenses of $500,000, 50 percent of which were related to the German branch taxable income. Euro Corporation, a U.S. corporation, operates through a branch in Germany. During 2019 the branch reported taxable income of $1,000,000 and paid German income taxes of $300,000. In addition, Euro received $50,000 of dividends from its 5 percent investment in the stock of Maple Leaf Company, a Canadian corporation. The dividend was subject to a withholding tax of $5,000 Euro reported U.S. taxable income from its manufacturing operations of $950,000. Total taxable income was $2,000,000. Precredit U.S. taxes on the taxable income were $420,000. Included in the computation of Euro's taxable income were "definitely allocable" expenses of $500,000, 50 percent of which were related to the German branch taxable income

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