Henry, a U$.$S$.$ citizen, is engaged in numerous, diverse operations and pays U$.$S$.$ income tax at a flat rate of $37\%.$ Henry owns a Limited Liability Company $($U$.$S$.$ LLC$),$ a domestic disregarded entity for U$.$S$.$ tax purposes. U$.$S$.$ LLC purchases widgets for resale in the United States. Sales in the United States result in $$100,000$ of net U$.$S$.-$source taxable income. Henry projects that he could earn approximately $$100,000$ of additional net foreign source taxable income in the United Kingdom $($the $"$U$.$K$."),$ where the U$.$K$.$ corporate taxable income is $$100,000$ and the U$.$K$.$ corporate income tax flat rate is $20\%.$ To further limit his liability $($widgets being a very dangerous product$),$ Henry$$s U$.$S$.$ LLC forms a private limited company in the U$.$K$.($U$.$K$.$ PLC$).$ The U$.$K$.$ PLC is not a "per se$"$ entity and, therefore, Henry $($via the U$.$S$.$ LLC$)$ would consider $$checking$-$the$-$box$$ to treat the U$.$K$.$ PLC as a foreign disregarded entity for U$.$S$.$ tax purposes. Assume that both the U$.$K$.$ withholding tax rate on any dividends from a U$.$K$.$ PLC to the United States is $15\%$ under the U$.$S$.-$U$.$K$.$ tax treaty and that the title on all widget sales passes in the U$.$K$.$

a$.$ If the U$.$K$.$ PLC is "checked," what is Henry's foreign tax credit position in Year $1$ if an $$80,000$ dividend is distributed by the U$.$K$.$ PLC to the United States from a U$.$K$.$ tax perspective?

b$.$ If the U$.$K$.$ PLC is "checked," what is Henry$$s foreign tax credit position in Year $1$ if a dividend is not distributed by the U$.$K$.$ PLC to the United States from U$.$K$.$ tax perspective?

c$.$ What is Henry's foreign tax credit position in Year $1$ if the U$.$K$.$ PLC is not "checked" as a foreign disregarded entity and an $$80,000$ dividend is distributed by the U$.$K$.$ PLC to the United States from a U$.$K$.$ tax perspective?

d$.$ What is Henry's foreign tax credit position in Year $1$ if the U$.$K$.$ PLC is not "checked" as a foreign disregarded entity and a dividend is not distributed by the U$.$K$.$ PLC to the United States from U$.$K$.$ tax perspective?

Clarification: If U$.$S$.$ LLC check$-$the$-$box, then they are treating U$.$K$.$ PLC as a foreign branch. If U$.$S$.$ LLC does not check$-$the$-$box, then they are treating U$.$K$.$ PLC as a foreign corporation. NOTE: In both cases, U$.$S$.$ LLC is a flow$-$thru entity $($i$.$e$.,$ they are not a U$.$S$.$ C$-$Corporation$).$