LO.4, 5 RedCo, a domestic corporation, incorporates GreenCo, a new wholly owned entity in Germany. Under both German and U.S. legal principles, this entity is a corporation.

RedCo faces a 35% U.S. tax rate.

GreenCo earns $800,000 in net profits from its German activities and makes no dividend distributions to RedCo. How much U.S. income tax will RedCo pay for the current year as a result of GreenCo’s earnings, assuming no deemed dividend under Subpart F?

Ignore any FTC implications.