Giant Corporation (a U.S. corporation) forms Small Corporation in a foreign country. Giant owns 70% of Small Corporation’s stock and the remaining stock is owned by citizens of the country in which Small is located.This year Small Corporation earns $1,500,000 of taxable income from its manufacturing operations and pays $200,000 in taxes to the foreign country in which it is located. Small does not make any dividend distributions. How much of Small Corporation’s taxable income will be subject to U.S. income tax this year?

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