7. LO.3 BlueCo, 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. BlueCo faces a 21% U.S. tax rate.

GreenCo earns $1,500,000 in net profits from its German manufacturing activities, and GreenCo makes no dividend distributions to BlueCo. How much Federal income tax will BlueCo pay for the current year as a result of GreenCo’s earnings, assuming that it incurs no deemed dividend under Subpart F?