U.S. individual owns 100% of an S corporation that owns 100% of a U.K. subsidiary (“UKSub”). UKSub has post-1986 undistributed earnings and profits of $500,000 and post-1986 foreign income taxes of $120,000. UKSub has never paid a dividend. Further assume that U.S. individual is in the 37% tax bracket. What is U.S. individual’s U.S. tax liability? What is the U.S. individual’s U.S. tax liability if UKSub distributes a $500,000 dividend?