USP is a domestic corporation. USP owns 100% of F, a foreign…
USP is a domestic corporation. USP owns 100% of F, a foreign corporation. During its first year of operations, F has $250,000 of pre-tax earnings and pays $35,000 in foreign income taxes. F’s $215,000 of E&P is attributable to $43,000 of Subpart F income and $172,000 of non-Subpart F income. What amount of US tax does USP owe by virtue of its ownership of F?
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