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Galaxy Corporation ( Galaxy ) , a U . S . corporation, manufactures binoculars, telescopes, and other optical equipment in its plant in San Diego,
Galaxy Corporation Galaxy a US corporation, manufactures binoculars, telescopes, and other optical equipment in its plant in San Diego, California. Galaxy conducts an extensive research and development operation in San Diego which has yielded numerous inventions in the optics area that have been patented in the United States and in most industrialized countries. Galaxy granted on January of year a nonexclusive license covering foreign patents on one of its important inventions to an unrelated company organized under the laws of the Czech Republic that manufactures special binoculars for use at night. On January of year Galaxy also acquired interestbearing debt obligations of foreign borrowers. These debt obligations produce yearly interest income of $ on which Galaxy pays $ of foreign income taxes. In addition, on January of year Galaxy established an export sales branch in Hungary to handle export sales of optical products Galaxy purchases from unrelated manufacturers in the United States. All income or loss of the branch is sourced in Hungary.Galaxys results for year were as follows:Galaxy received $ of foreignsource interest income on which it paid $ of foreign income tax. Galaxy received royalties from the Czech licensee of $ which were subject to a Czech withholding tax of percent $The Hungarian sales branch had a loss of $Galaxy had $ of taxable income from its US operations all sourced in the United States.Assume that Galaxys effective US tax rate is percent and that all years start after Under Section how much foreign tax will Galaxy be allowed to credit for year
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