DomCo is a wholly-owned U.S. subsidiary of AbroadCo, a foreign corporation. DomCo's assets include cash of $500,000, accounts receivable of $500,000, and its U.S. manufacturing plant with a value of $2 million. AbroadCo sells its shares to a buyer for $3,800,000. Which of the following best describes the tax implications?

a)

The buyer does not have to withhold because is the sale of stock.

b)

The buyer must withhold $200,000.

c)

The buyer must withhold $120,000.

d)

The buyer must withhold $570,000 under FIRPTA, since DomCo is a U.S. Real Property Holding Corporation.