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Horton Corporation Is a 100 Percent Owned Canadian Subsidiary of Cruller

question 95

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Horton Corporation is a 100 percent owned Canadian subsidiary of Cruller Corporation,a U.S.corporation.Horton had post-1986 earnings and profits of C$2,400,000 and post-1986 foreign taxes of $1,600,000.During the current year,Horton paid a dividend of C$600,000 to Cruller.The dividend was characterized as general category income for FTC purposes.The dividend was subject to a withholding tax of C$30,000.Assume an exchange rate of C$1 = $1.Cruller reported U.S.sourced taxable income of $2,000,000 before considering the dividend received from Horton Corporation.Cruller's U.S.tax rate is 34 percent.Compute the tax consequences to Cruller as a result of this dividend.

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