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To determine the foreign tax credit, it's essential to calculate the actual foreign taxes paid by the subsidiary based on its pre-tax income and the foreign tax rate. In this scenario, the U.K. subsidiary has a pre-tax income of $1 million and a tax rate of 40%.

First, calculate the amount of tax that the subsidiary owes. This is done by multiplying the pre-tax income by the tax rate:

Tax owed = Pre-tax income × Tax rate

Tax owed = $1,000,000 × 0.40 = $400,000

The foreign tax credit that may be applied on the U.S. tax return corresponds to the amount of foreign tax paid, which in this case is $400,000. The foreign tax credit allows taxpayers to reduce their U.S. tax liability by the amount of taxes they have already paid to foreign governments, thus preventing double taxation on the same income.

Therefore, the correct answer reflects the total foreign taxes paid by the subsidiary, which can be claimed as a credit against U.S. taxes. This aligns with tax regulations regarding credits for foreign taxes, emphasizing the importance of understanding how foreign tax amounts translate into potential credits when filing a U.S. tax return.