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 the U.S. creditable foreign taxes of Topco, Inc. due to the Subpart F income generated by Topco Ltd. (Ireland)?
   1. $-0-.
   2. $1.89 million.
   3. $1 million.
   4. $0.6 million.
   5. $2.1 million.