U.S. International Corporation (USIC), a U.S. taxpayer, has investments in Foreign Entities A-G. Relevant Information for these entities for the current fiscal year appears in the following table:

Entity	Country	% Owned	Activity	Income before tax ($ millions)	Income Tax Rate	Dividend Withholding tax Rate	Net Amount Received by Parent ($ millions)
USIC	United States		Manufacturing	$10.00	35.00%
A	Argentina	100%	Manufacturing	$1.00	35.00%	0%	$0.20
B	Brazil	100%	Manufacturing	$2.00	34.00%	0%	$2.50
C	Canada	100%	Manufacturing	$3.00	26.00%	5%	$1.00
D	Hong Kong	100%	Investment	$2.00	16.50%	0%	$1.50
E	Liechtenstein	100%	Distribution	$3.00	10.00%	4%	$ -
F	Japan	51%	Manufacturing	$2.00	38.00%	5%	$0.50
G	New Zealand	60%	Banking	$4.00	28.00%	5%	$1.00

Additional Information

1. USICs $10 million income before tax is derived from the production and sale of products in the United States.

2. Each entity is legally incorporated in its host country other than Entity A, which is registered with the Argentinian government as a branch.

3. Entities A, B, C, and F produce and market products in their home countries.

4. Entity D makes passive investments in stocks and bonds in the Hong Kong financial markets. Income is derived solely from dividends and interest.

5. Entity E markets goods purchased from (manufactured by) USIC. Of Es sales, 95% are made in Austria, Germany, and Switzerland, and 5% are made in Liechtenstein.

6. Entity G operates in the financial services industry in New Zealand.

Required

Determine the following:

c. The net U.S. tax liability.

d. Any excess foreign tax credits (identify by basket).