Which of the following foreign taxes is not creditable for U.S. tax purposes?
A) Direct taxes paid by a U.S. corporation on income earned in a foreign branch.
B) Income taxes paid to a foreign taxing authority on a dividend received by a U.S. corporation from its 100 percent owned foreign subsidiary.
C) Withholding taxes imposed on a dividend received by a U.S. corporation from its 100 percent owned foreign subsidiary.
D) All of these taxes are creditable.
Answer: C