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FORco, a foreign corporation, owns 100% of the shares of USAco, a U.S. corporation that derives all of its income from U.S. business operations. During
FORco, a foreign corporation, owns 100% of the shares of USAco, a U.S. corporation that derives all of its income from U.S. business operations. During its first year of operations, USAco has taxable income of $20 million and distributes all of its after-tax earnings to FORco. Assume no change in U.S. net equity during the year, a U.S. corporate tax rate of 21%, and a U.S. withholding rate for U.S.-source dividends is 5%. How much is the total U.S. tax burden on USAcos repatriated earnings?
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