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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 5 0 percent -
Windmill Corporation manufactures products in its plants in lowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada
through a percentowned Joint venture, CanCo. CanCo is treated as a corporation for US and Canadian tax purposes. An unrelated
Canadian investor owns the remaining percent. Windmill conducts its operations in Ireland through a wholly owned subsidiary, IrishCo.
IrishCo is a controlled foreign corporation for US tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid
entity, KiwiCo. KiwiCo Is treated as a branch for US tax purposes and a corporation for Australlan tax purposes. Windmill also owns a percent
Interest in a Dutch corporation, TulipCo.
During Windmill reported the following foreign source income from its international operations and investments.
Note: CanCo and KiwiCo derive all of their earnings from active business operations. b Windmill has $ of US source gross income. Windmill also incurred SG&A of $ that is apportioned between US and
foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $ Compute the FTC limitation
for each basket of foreign source income.
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Windmill has $ of US source gross income. Windmill also incurred SG&A of $ that is apportioned between
US and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $
Compute the FTC limitation for each basket of foreign source income.
Note: Do not round any division. Round other intermediate computations and final answers to the nearest whole dollar
amount.
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