Ronan, Inc. is a U.S. corporation and Becker, Inc. is its foreign subsidiary. In 2017, Ronan earned $400,000 of U.S. source income. Becker earned $100,000 of foreign income, paid $20,000 of foreign tax, and distributed $80,000 to Ronan. Ronan will report $ of taxable income this year and claim $ of foreign tax credit