Wally World, Inc. $($Wally$),$ a U$.$S$.$ C$-$Corporation with a calendar year end, manufactures widgets in its plant in Saugatuck, Michigan. On January $1,2022,$ Wally forms a wholly$-$owned subsidiary in the United Kingdom $($UK$),$ Pub Limited $($Pub$),$ which also has a calendar year end and is treated as a foreign corporation for U$.$S$.$ tax purposes. Pub purchases widgets manufactured by Wally in the United States and markets, sells, and distributions these products throughout the UK$.$

In calendar year $2022,$ Pub generated $$2,500,000$ of foreign$-$source taxable income, under U$.$S$.$ tax principles, and paid $$450,000$ of U$.$K$.$ corporate income tax, resulting in CFC tested income of $$2,050,000.$ For the record, Wally is not a U$.$S$.$ shareholder in any other foreign corporation. Also, for calendar year $2022,$ Pub$$s Qualified Asset Business Investment $($QABI$)$ was $$500,000,$ and no interest expense deduction was taken into account in determining Pub$$s foreign$-$source taxable income.

In calendar year $2022,$ Wally$$s deduction eligible income was $$120,000,000,$ and its foreign$-$derived deduction eligible income $$24,000,000.$ Also, for calendar year $2022,$ Wally$$s Qualified Asset Business Investment $($QABI$)$ was $$800,000,000.$

Assume that Wally$$s $2022$ corporate income tax return only includes deduction eligible income and its Global Intangible Low$-$Taxed Income $($GILTI$)$ inclusion from Pub, plus the IRC Section $78$ gross$-$up$.$ Furthermore, no deductible U$.$S$.-$based expenses are allocated and apportioned against the GILTI inclusion. Also, assume the flat U$.$S$.$ corporate income tax rate is $21$ percent.

$($a$.)$ Calculate Wally$$s Global Intangible Low$-$Taxed Income $($GILTI$)$ inclusion and its Foreign$-$Derived Intangible Income $($FDII$)$ deduction, including U$.$S$.$ taxable income and the U$.$S$.$ residual tax, if any, due after taking an IRC Section $960$ deemed foreign tax credit.

$($b$.)$ If Wally were to pay a dividend in calendar year $2022$ and one of its shareholders was a foreign individual residing in a country that does not have a bilateral income tax treaty with the United States, are there any U$.$S$.$ withholding tax requirements with respect to this dividend payment? Please explain.