Blue Horizons, Inc., a U.S. corporation, is a manufacturing concern that sells most of its products in the United States. It also does some business in the European Union through various branches. During the current year, Blue Horizons has taxable income of $700,000, of which $500,000 is U.S.-sourced and $200,000 is foreign-sourced.
Foreign income taxes paid amounted to $45,000. Blue Horizons's U.S. income tax liability is $238,000. What is its U.S. income tax liability net of the allowable foreign tax credit?