Foreign Corporation A operates a USTB that has, as of January $1,2022,$ $$9,000$ in accumulated ECEP, $$25,000$ in USNE, and no ECEP as through January $1,2022.$ As of December $31,2022,$ Foreign Corporation A has $$8,000$ of ECEP for $2022$ and $$30,000$ of USNE.

What would Foreign Corporation A$\text{'}$s DEA for $2022$ be if$,$ instead of incorporating, it entirely terminated its USTB at the end of $2022?$

Rule:

Analysis:

Conclusion: