u.s taxation of foreign branch income given data hungarian branch pre-tax income in year 1 50,000,000 dividend repatriated on december 15, year 1 income tax rates hungarian tax rate 9% U.S. TAX RATE 21% exchange rates for year 1 usd per 1 huf january 1 0.0030 average for the year 0.0032 december 15 0.0033 december 31 0.0035 determine the amount of U.S. taxable income