USCO, a U.S. company, opens a branch in Country X on January 1, 2022. The Country X branch generates a 2022 calendar year loss of ($200,000). When combining USCO's Country X 2022 branch loss with USCO's pre-tax net income of $200,000 from its U.S. operations, USCO has 2022 taxable income of $-0-. In 2023, assume: 1-The Country X branch generates $200,000 of pre-tax net income 2-USCO's U.S. operations again generate pre-tax net income of $200,000; and 3- USCO pays 30% foreign tax on its Country X pre-tax net income of $200,000 and USCO is in the 21% U.S. tax bracket. As a consequence of the overall foreign loss recapture rule and assuming USCO does not elect to recapture an additional amount, USCO's foreign tax credit limitation for 2023 will be?

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To calculate USCOs foreign tax credit limitation for 2023 we need to consider the foreign tax paid t... View the full answer