Thank you and apologies for that, I haven't done this adjustment before, unsure what is impacting the calculation.

The only thing being taxed at the reduced 15% cap gain tax rate is the $75k foreign CGD. The rest of the income is being taxed at the marginal rates.  So I assumed there would still be need for the adjustment.  Are you saying I do not need to do this differential adjustment at all on Form 1116?