BlueCo, a domestic corporation, incorporates GreenCo, a new wholly owned entity in Germany. Under both German and U.S. legal principles, the entity is a corporation. BlueCo faces a 35% tax rate. GreenCo earns $1,500,000 in net profits from its German activities and makes not dividend distributions to BlueCo.

How much U.S. income tax will BlueCo pay for the current year as a result of GreenCos earnings, assuming no deemed dividend under Subpart F?