Flora Corporation, a U.S. corporation that manufactures imitation flowers owns 100% of the stock of Danica Corporation,

[answerhappygod]

Flora Corporation, a U.S. corporation that manufactures
imitation flowers owns 100% of the stock of Danica Corporation, a
foreign sales subsidiary that was organized in Year 1. It
contributed $2,000,000 in exchange for the Danica stock. During
Year 1, Danica had $60 million of foreign base company sales
income, paid $12 million in foreign income taxes, and did not
distribute any dividend. During Year 2, Danica had no earnings and
profits, paid no foreign income taxes, and distributed a $48
million dividend which was subject to 10% foreign withholding tax.
The U.S. corporate tax rate is 35%.
For Year 2, what amount of the $48 million distribution is
subject to U.S. taxation? Please explain your answer.
$48 million
$43.2 million
0
$24 million