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USCo, a C corporation, owns FORco, a foreign corporation. On December 31, 2017, FORco has $5 million of earnings and profits, $2 million of which
USCo, a C corporation, owns FORco, a foreign corporation. On December 31, 2017, FORco has $5 million of earnings and profits, $2 million of which are attributable to cash or cash equivalents. What is the amount of the transition tax (a/k/a Deemed Repatriation Regime)?
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