Question: KeenCo, a domestic corporation, is the sole shareholder of LovettCo, a controlled foreign corporation. LovettCo has $250,000 in E&P attributable to income not previously taxed to KeenCo and $200,000 E&P attributable to income taxed to the U.S. shareholder as Subpart F income. LovettCo makes a $125,000 dividend distribution to KeenCo. Ignoring any demmed paid credit implications, what is the U.S. gross income to KeenCo resulting from this dividend?