The company Think Tankards has a stable foreign income, which is taxed at a low rate abroad. In each of the three preceding income years, it effectively paid usd 50m in additional US taxes on foreign income, and it expects to do the same for the years to come. For the current year, however, there is a usd 100m excess foreign tax credit. How is this excess credit treated under each of the following carry-forward/carry-back rules? What is the present value of the loss if future tax breaks are discounted at 15 percent?
(a) No carry-back, one-year carry-forward.
(b) No carry-back, two-year carry-forward.
(c) One-year carry-back, two-year carry-forward.
(d) Two-year carry-back, two-year carry-forward.