Creator, a U.S. person, invents the cure for cancer in his basement. Creator transfers the cure for cancer to a company in the Cayman island (CAYco), which does not have to pay any income tax under cayman islands law. For US tax purposes, the transaction is treated as:

(a) a tax-free incorporation

(b) a one-time sale by creator to the cayman islands company.

(c) a sale in return for a series of annual royalty payments

(d) none of above