Mary, a U.S. citizen, is the sole shareholder of CanCo, a Canadian corporation. During its first year of operations, CanCo earns $14 million of foreign-source taxable income, pays $6 million of Canadian income taxes, and distributes a $2 million dividend to Mary. Can Mary claim a deemed-paid (indirect) foreign tax credit on her Form 1040 with respect to receipt of a dividend distribution from CanCo? Why or why not?
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