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Windmill Corporation manufactures products in its plants in lowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50 percent owned joint
Windmill Corporation manufactures products in its plants in lowa, 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. Irish Co 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 2020, Windmill reported the following foreign source income from its international operations and investments. CanCo Irishco KiwiCo TulipCo $60,600 $64,400 3,030 3,220 $30,400 4,560 Dividend income Amount Withholding tax Interest income Amount Withholding tax Branch income Taxable income AUS income taxes $43,000 0 0 $112,500 $ 37,500 Note: CanCo and KiwiCo derive all of their earnings from active business operations. Requirement: a. Classify the income received by Windmill into the appropriate FTC baskets. b. Windmill has $1,276,000 of U.S. source gross income. Windmill also incurred SG&A of $326,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $287,100. Compute the FTC limitation for each basket of foreign source income
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