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.

2. 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.

3. What is Topco, Inc. allowed foreign tax credit for the General Income category for 2019?
   1. $-0-.
   2. $3.5 million.
   3. $10 million.
   4. $1.89 million.
   5. $0.6 million

4. Assume the facts from above and Topco Ltd. (Ireland) has depreciable tangible assets used to generate operating income for 2019 and the average quarterly adjusted tax basis of the tangible assets is $15,000,000 and net specified interest expense of $500,000 not included in Topco Ltd. (Ireland) tested income. What is the Topco, Inc.s GILTI Amount under Sec. 951A(b)(1) for 2019?
   1. $-0-.
   2. $12.2 million.
   3. $1.5 million.
   4. $20.0 million.
   5. $10 million.