FORco wants to open a sales office in the United States. Because FORco does not want to be subject to any withholding tax on dividends, FORco does not form a U.S. subsidiary, but instead operates in the U.S. as a branch. If the U.S. sales office is profitable and distributes cash, FORco may be subject to:

(a) the withholding tax on dividends only.

(b) the branch profits tax only.

(c) both the withholding tax on dividends and the branch profits tax.

(d) transfer pricing penalties.