USCo, a domestic corporation, has worldwide taxable income of $500,000, including a $300,000 dividend from ForCo, a wholly owned foreign corporation. ForCo has $1,000,000 in post-1986 undistributed E & P, and it has paid $200,000 of foreign income taxes attributable to these earnings.

All foreign income is in the general limitation basket.

Before consideration of any limitation, USCo's deemed-paid FTC related to the dividend received isceived is