FORco, a country F corporation, declares a $100 dividend to USAco, its U.S. parent corporation. Pursuant to the law of F, FORco withholds $10 of withholding tax and pays the remaining $90 to USAco. Because of the withholding tax, USAco is not liable for any additional country F's income taxes on the dividend. The $10 of withholding tax is:

(a) creditable because the tax passes the net income requirement

(b) not creditable because the tax does not pass the net income requirement

(c) creditable as an in-lieu-of tax

(d) not creditable as an in-lieu-of tax