A US-Based MNC Has Three Subsidiaries: S1 (40 Percent Owned by by the MNC);

Essay

A U.S.-based MNC has three subsidiaries: S1 (40 percent owned by the MNC); S2 (33 percent owned by S1), and S3 (20 percent owned by S2). The taxable income for each firm is $100 million. The local taxes for each firm are $15 million, $20 million, and $10 million, respectively. The MNC's tax rate is 40 percent.
(a) Can the MNC apply all of its local taxes as a credit against its U.S. taxes?
(b) Based on the "grossing up" concept, calculate all tax credits applicable to the MNC.