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Sombrero Corporation, a U.S. corporation, operates through a branch in Espania. Management projects that the company’s pretax income in the next taxable year will be $174,600, $149,000 from U.S. operations and $25,600 from the branch. Espania taxes corporate income at a rate of 45 percent. The U.S. corporate tax rate is 35 percent. If management’s projections are accurate, what will be Sombrero’s excess foreign tax credit in the next taxable year? Assume all of the income is general category income.
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