Locket, a U.S. C corporation, makes a sale to a customer in Sustainia, a country that applies a 25% income tax to business profits. The customer found out about Locket through an Internet search. Locket has no facilities or employees outside the United States. Locket's profit on the sale totals $25,000. Where is the tax levied on this profit? 30. LO.5 USCo incorporated its foreign branch operations in Italy by transferring the branch's assets to a foreign corporation in return solely for stock in the new corporation. All of the branch's assets are located outside the United States and are used in the active conduct of a foreign trade or business. Is this transaction automatically eligible for tax deferral under § 351? Explain.