P is a domestic corporation. In each of the following independent scenarios, identify the foreign corporations (F1 through F4) for which P can claim a deemed paid foreign tax credit, assuming the foreign corporation’s earnings are distributed up to P.
a. P owns 50% of F1, F1 owns 50% of F2, and F2 owns 50% of F3.
b. P owns 100% of F1, F1 owns 100% of F2, and F2 owns 9% of F3.
c. P owns 100% of F1, F1 owns 100% of F2, F2 owns 100% of F3, and F3 owns 50% of F4. All the other shareholders of F4 are unrelated foreign persons.
d. P owns 100% of F1 and 100% of F2. F1 owns 5% of F3, and F2 owns 5% of F3.