Amelia,Inc.,a domestic corporation,has worldwide taxable income of $8 million,including a $600,000 dividend from ForCo,a wholly-owned foreign corporation.ForCo's post-1986 undistributed E & P are $18 million and it has paid $12 million of foreign income taxes attributable to these earnings.What is Amelia's deemed paid foreign tax credit related to the dividend received (before consideration of any limitation)?

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The deemed paid credit under § 902 is based on the ratio of dividend (or deemed dividend)income to the pool of post-1986 E & P multiplied by the pool of foreign income taxes attributable to this E & P.The deemed paid credit in this case is equal to $400,000 [($600,000/$18 million)F1F1F1S1F1F1F10 $12 million].