Topco, Inc., a corporation organized in the U.S., owns 100% of the stock of Topco Ltd., a foreign corporation organized in Ireland, and has no other foreign entities owned or foreign operations. For the 2019 tax year, Topco Ltd. (Ireland) earned net income of $17,600,000 from manufacturing and sales operations, after taxes at a 12% tax rate. Of the 2019 Topco Ltd. foreign pre-tax earnings, $5 million represents Foreign Based Company Sales Income on which Topco Ltd. incurred Ireland income tax at a 12% tax rate.

1. What is Topco, Inc. Sec. 904 U.S. foreign tax credit limitation in the General Income category for the 2019 tax year?
   1. $-0-.
   2. $2.1 million only in the high-tax income category limitation.
   3. $1.05 million.
   4. $5.0 million.
   5. $10.0 million.

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