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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

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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 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, Tulip Co. During 2020, Windmill reported the following foreign source income from its international operations and investments. Canco Irisho Kiwico Tulipco Dividend income Amount $60,600 $64,400 $30,400 Withholding tax 3,830 4,560 Interest income Amount $43,000 Withholding tax Branch income Taxable income $112,500 AUS income taxes $ 37,500 3,220 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 $287100. Compute the FTC limitation for each basket of foreign source income

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