Ramy Corporation, a U.S Corporation, incorporates Amr Corporation, a new wholly owned entity in Germany. Under both U.S. and German law, this entity is a corporation. Ramy Corporation faces a 35% U.S. Tax rate and Amr Corporation faces a 20% German Tax rate. Germany also imposes a 5% withholding tax on dividends.

Amr earns $1,500,000 in net profits from its German activities. How much U.S. income tax will Ramy Corporation pay for the current year as a result of Amr Corporations earnings, assuming (1) no dividend payment, (2) a dividend payment, and (3) characterization of the earnings as Subpart F Income. Explain.