Rainier Corporation, a U.S.
corporation, manufactures and sells quidgets in the United States,
Europe and the Middle East. Rainier conducts its operations in
Europe and the Middle East through a German GmbH, which the company
elects to treat as a branch, i.e. DRE, for U.S. tax purposes.
Rainier also licenses the rights to manufacture quidgets to an
unrelated company in China. During the current year, Rainier paid
the following foreign taxes, translated into U.S. dollars at the
appropriate exchange rate:...