Each of the following statements regarding the tax implications for a foreign subsidiary or a foreign branch is correct, except:

A. A foreign branch's net income is subject to U.S federal income tax.

B. A U.S. corporation receiving dividends from a foreign subsidiary is generally eligible for a 100% dividends received deduction.

C. A foreign subsidiary's net income is not subject to U.S. federal income tax.

D. A U.S. parent company of a foreign subsidiary may use the losses of the subsidiary to offset its income