Trace, Ltd., a foreign corporation, operates a trade or business in the United States. Traces U.S.-source income effectively connected with this trade or business is $800,000 for the current year. Traces current-year E & P is $600,000. Traces net U.S. equity was $8.2 million at the beginning of the year and $8.6 million at year-end. Trace is a resident in a country that has no income tax treaty with the United States. Prepare a letter to Tanner Martin, Traces Tax VP, reporting Traces branch profits tax liability for the current year, along with at least one planning idea for reducing the branch profits tax.