USP is а dоmestic cоrpоrаtion. USP owns 100% of F, а foreign corporation. During its first year of operations, F has $500,000 of pre-tax earnings and pays $70,000 in foreign income taxes. F’s $430,000 of E&P is attributable to $86,000 of Subpart F income and $344,000 of non-Subpart F income. What amount of US tax does USP owe by virtue of its ownership of F?