LO.5 USCo, a domestic corporation, reports worldwide taxable income of $1.5 million, including a $400,000 dividend from ForCo, a wholly owned foreign corporation. ForCo holds $16 million in undistributed E & P, and it has paid $10 million of foreign income taxes attributable to these earnings. All foreign income is in the general limitation basket.

What is USCo’s deemed-paid FTC related to the dividend received (before consideration of any limitation)?