King, a U.S. corporation, owns 25% of each of two foreign corporations. King's foreign business activities are taxed at foreign tax rates that are higher than those prevailing in the United States. Consequently, King finds itself in an excess foreign tax credit position. Corporation A is located in a country that has concluded a tax treaty with the United States. The treaty reduces from 15% to 5% the withholding on dividends paid to a U.S. corporation. Corporation B is located in a non-treaty country where the withholding rate is 15%. A and B both pay local income taxes at a 20% effective tax rate. If King wants to repatriate profits, which corporation(s) should pay the dividend to minimize the repatriation cost? Can King use such a payment to reduce its excess foreign tax credits associated with its other foreign income?