BlueCo, a domestic corporation, incorporates GreenCo, a new wholly owned entity, in Germany. Under both German and U.S. legal principles, this entity is a corporation. BlueCo faces a 21% U.S. tax rate. GreenCo earns $1,500,000 in net profits from its German manufacturing activities and makes no dividend distributions to BlueCo. Ignore any FTC implications. How much U.S. income tax must BlueCo pay for the current year as a result of GreenCo's earnings, assuming that it triggers no constructive dividend under Subpart F