Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a $50$ percent$-$owned joint venture, CanCo. CanCo is treated as a corporation for U$.$S$.$ and Canadian tax purposes. An unrelated Canadian investor owns the remaining $50$ percent. Windmill conducts its operations in Ireland through a wholly owned subsidiary, IrishCo. IrishCo is a controlled foreign corporation for U$.$S$.$ tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid entity, KiwiCo. KiwiCo is treated as a branch for U$.$S$.$ tax purposes and a corporation for Australian tax purposes. Windmill also owns a $5$ percent interest in a Dutch corporation, TulipCo.

During $2023,$ Windmill reported the following foreign source income from its international operations and investments.

CanCo IrishCo KiwiCo TulipCo

Dividend income

Amount $ $66,600$ $ $78,400$ $ $34,400$

Withholding tax $3,3303,9205,160$

Interest income

Amount $ $48,000$

Withholding tax $00$

Branch income

Taxable income $ $120,000$

AUS income taxes $ $40,000$

Note: CanCo and KiwiCo derive all of their earnings from active business operations.

Required:

Classify the income received by Windmill into the appropriate FTC baskets.

Windmill has $$1,286,000$ of U$.$S$.$ source gross income. Windmill also incurred SG&A of $$336,000$ that is apportioned between U$.$S$.$ and foreign source income based on the gross income in each basket. Assume KiwiCo$$s gross income is $$320,600.$ Compute the FTC limitation for each basket of foreign source income.