BrazilCo, Inc., a foreign corporation with a U.S. trade or business, has U.S.-source income as follows.
Dividend income from unrelated investment activities
$ 50,000
Net U.S.-source effectively connected income
600,000
Determine BrazilCo's total U.S. tax liability for the year, assuming a 35% corporate rate and no tax treaty. BrazilCo leaves its U.S. branch profits invested in the United States, and it does not otherwise repatriate any of its U.S. assets during the year.
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