Finco is a wholly owned Finnish manufacturing subsidiary of Winco, a domestic corporation that manufactures and markets residential window products throughout the world. Winco has been Finco's sole shareholder since Finco was organized in 2010. At the end of the current year, Winco sells all of Finco's stock to an unrelated foreign buyer for $25 million. At that time, Finco had $6 million of post-1986 undistributed earnings, and $2 million of post-1 986 foreign income taxes that haye not yet been deemed paid by Winoo. Winco's basis in Finco's stock was $5 million immediately prior to the sale