Windmill Corporation manufactures products in its plants in Iowa, Canada, Ireland, and Australia. Windmill conducts its operations in Canada through a 50 percent owned joint venture, CanCo. CanCo is treated as a corporation for U.S. and Canadian tax purposes. An unrelated Canadian investor owns the remaining 50 percent. Windmill conducts its operations in Ireland through a wholly owned subsidiary, IrishCo. IrishCo is a controlled foreign corporation for U.S. tax purposes. Windmill conducts its operations in Australia through a wholly owned hybrid entity (KiwiCo) treated as a branch for U.S. tax purposes and a corporation for Australian tax purposes. Windmill also owns a 5 percent interest in a Dutch corporation (TulipCo).
During 2015, Windmill reported the following foreign source income from its international operations and investments.

Notes to the table:
1. CanCo and KiwiCo derive all of their earnings from active business operations.
2. The dividend from CanCo carries with it a deemed paid credit (§78 gross-up) of $30,000.
3. The dividend from IrishCo carries with it a deemed paid credit (§78 gross-up) of $4,000.
a) Classify the income received by Windmill and any associated §78 gross-up into the appropriate FTC baskets.
b) Windmill has $1,250,000 of U.S. source gross income. Windmill also incurred SG&A of $300,000 that is apportioned between U.S. and foreign source income based on the gross income in each basket. Assume KiwiCo's gross income is $93,000. Compute the FTC limitation for each basket of foreign source income. The corporate tax rate is 35 percent.

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Canco IrishCo KiwiCo Tulipco Dividend income $28,000 $45,000 $20,000 3,000 Amount Withholding tax 2,250 1,400 Interest income Amount 30,000 Withholding tax Branch income $93,000 Taxable income AUS income taxes 31,000