IrishCo, a manufacturing corporation resident in Ireland, distributes products through a U.S. office. Current-year taxable income from such sales in the United States is $12 million. IrishCo's U.S. office deposits working capital funds in short-term certificates of deposit with U.S. banks. Current-year interest income from these deposits is $150,000.
IrishCo also invests in U.S. securities traded on the New York Stock Exchange.
This investing is done by the home office. For the current year, IrishCo records realized capital gains of $300,000 and dividend income of $50,000 from these stock investments. Compute IrishCo's U.S. tax liability, assuming that the U.S.-Ireland income tax treaty reduces withholding on dividends to 15% and on interest to 5%.
Assume a 34% U.S. tax rate.