FC, a Canadian company, bought 20% of a small private US company ("USCO") years back for investment purposes and a few years ago, FC opened a branch in the United States. The branch manufactures luggage for sale throughout the United States. In 2023, USCO pays FC a dividend of $200,000 and FC's US branch generates taxable income of $100,000. Consider the US-Canada Income Tax Treaty and any Protocols thereto (i.e., revisions) for any potential impact as to your answer. 

How will the US tax FC on its dividend income from USCO?