In 2022, FC, a Country X service company with substantial tangible property in Country X, is owned no tangible property in Country X. 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 $750,000 after-tax income. (i.e., all of its $1 Million in earnings net of the Country X income tax), which shareholders have to include in gross income his, her or its pro-rata share of the GILTI:

USCO, A, and the unrelated RAs

USCO only

USCO and A

None of the above