For the December 31, 2018 tax year ABCo, a domestic corporation, manufactures hockey sticks for sale globally. ABCo owns 100% of the stock of EFCo, a foreign manufacturing subsidiary that was organized in Year 1. During Year 1, EFCo had $18 million of foreign base company sales income (FBCSI), paid $4.5 million in foreign income taxes and distributed no dividends. During Year 2, EFCo had no earnings and profits, paid no foreign income taxes and distributed a $12 million dividend.

Assuming the US corporate income tax rate is 21%, what are the US tax consequences of EFCo's Year 1 and Year 2 activities? Assume the functional currency of EFCo is the USD.