On April 1, 2008, Irvan, a US corporation, acquired for $300,000 all the stock in DeLeon, a foreign corporation. At the close of business on September 30, 2010, Irvan sells the Deleon's 2008-2010 activities. DeLeon reports E&P balances for the period as follows: year 2008 E&P $120,000 year 2009 E&P 110,000 year 2010 E&P 144,000
a. What are the amount and character of Irvan's gain on the sale of the DeLeon stock? b. Can Irvan use any of DeLeon foreign taxes to reduce its U.S. tax liability on the stock gain?