In 2022, FC, a Country X manufacturing company with substantial tangible property in Country X, is owned 30% by USCO, 25% by A, a U.S. citizen, and 9% each by 5 unrelated RAs. During 2022, FC generated operating income in Country X of $1 Million and FC paid Country X income tax of $250,000. Assume that FC has no subpart F income nor any global intangible low-tax intangible income ("GILTI") during 2022. If FC pays a dividend of $750,000 (i.e., all of its $1 Million in earnings net of the Country X income tax), which of FC's shareholders will benefit from the new 100% dividends received deduction (participation exemption):

USCO, A, and the unrelated RAs

USCO only

A only

USCO and A

None of the above