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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 U.S. 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 1 of year 1 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 1 of year 1, Galaxy also acquired interest-bearing debt obligations of foreign borrowers. These debt obligations produce yearly interest income of $300,000 on which Galaxy pays $45,000 of foreign income taxes. In addition, on January 1 of year 1, 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 1 were as follows:Galaxy received $300,000 of foreign-source interest income on which it paid $45,000 of foreign income tax. Galaxy received royalties from the Czech licensee of $100,000, which were subject to a Czech withholding tax of 10 percent ($10,000).The Hungarian sales branch had a loss of $100,000.Galaxy had $700,000 of taxable income from its U.S. operations all sourced in the United States.Assume that Galaxys effective U.S. tax rate is 21 percent and that all years start after 2017. Under Section 904, how much foreign tax will Galaxy be allowed to credit for year 1?

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