DomCo (a domestic corporation) owns 100% of ForCo (a foreign corporation), which operates outside of the United States. Which of the following statements is correct?

a. ForCo is not considered a controlled foreign corporation (CFC).

b. ForCo’s Subpart F income will generally be treated as deemed dividend subject to immediate recognition by DomCo.

c. ForCo’s income will be subject to current taxation in the United States because ForCo is a foreign subsidiary.

d. ForCo is considered a foreign branch of DomCo.