$FC,$ a corporation formed in country $x,$ owns all the stock of $DC,$ a domestic corporation that is a U$.$S$.$ real property holding corporation. $DC$ makes a nonliquidating distribution of cash of $$1,000$ to $FC$ at a time when $DC\text{'}$s earnings and profits are $$100.FC$ has an adjusted basis in its $DC$ stock of $$500.$ What are the U$.$S$.$ tax consequences to $FC$ and the withholding requirements of $DC,$ assuming no tax treaty applies? See IRC $301(c),316,1445(e)(3)$; Reg. $1\mathrm{.}1441-3(c)(4),1\mathrm{.}1445-5(e).$

$FC,$ a corporation formed in country $x,$ owns all the stock of $DC,$ a domestic corporation that is a U$.$S$.$ real property holding corporation. $DC$ makes a nonliquidating distribution of cash of $$1,000$ to $FC$ at a time when $DC\text{'}$s earnings and profits are $$100.FC$ has an adjusted basis in its $DC$ stock of $$500.$ What are the U$.$S$.$ tax consequences to $FC$ and the withholding requirements of $DC,$ assuming no tax treaty applies? See IRC $301(c),316,1445(e)(3)$; Reg. $1\mathrm{.}1441-3(c)(4),1\mathrm{.}1445-5(e).$