What are the U.S. tax consequences of Filigree’s 2003 activity?

Filigree Inc., a foreign corporation, is a wholly owned subsidiary of Gold Corporation,
a U.S. corporation. Filigree’s 2003 taxable income of $1 million included $300,000 of Subpart F income. Filigree paid $270,000 of foreign income tax and made no distributions
to Gold during 2003. Gold’s separate company 2003 taxable income was
$2 million, all of which was U.S. source.
a. What are the U.S. tax consequences of Filigree’s 2003 activity?
b. Calculate Gold’s 2003 taxable income, allowable foreign tax credit, and net U.S.
tax liability.