U.S. International Corporation (USIC), a U.S taxpayer, has investment in Foreign Entities A-G. Relevant information for these entities for the current fiscal years appears in the following table:

 

 

Entity Country Percent Activity Income Income Dividend Net amount

Owned before tax tax rate withholding received by

$millions tax rate parent $mil.

 

USIC US ----- Manufacturing $10 35% ---- ----

 

A Argentina 100% Manufacturing 1 35% 0% $0.2

 

B Brazil 100% Manufacturing 2 34% 0% $2.5*

C Canada 100% Manufacturing 3 33% 5% $1.0

 

D Hong Kong 100% Investment 2 16.5% 0% $1.5

 

E Liechtenstein 100% Distribution 3 10% 4% $0.0

 

F Japan 51% Manufacturing 2 40% 5% $0.5

 

G New Zealand 60% Banking 4 30% 15% $1.0

 

 

*Some dividends were paid out of beginning-of-year retained earnings.

 

Additional Information

 

1. USIC;s $10 million income before tax is derived from the production and sale of products in the United State
2. Each entity is legally incorporated in its host country other than Entity A, which is registered with the Argentinian government as a branch.
3. Entities A,B,C and F produce and market products in their home countries
4. Entity D makes passive investments in stocks and bonds in the Hong Kong financial markets. Income is derived solely from dividend and interest

 

Required

 

Determine the following:

 

1. The amount of U.S. taxable income for each Entity A-G

2. The foreign tax credit allowed in the United State, first by basket and then in total

3. The net U.S tax liability

4. Any excess foreign tax credits (identify by basket)