Topco, Inc., a corporation organized in the U.S., has a manufacturing and sales operation located in Germany to serve Topco, Inc.s Germany based customers, with no other foreign entities or operations in the Topco, Inc. structure. In 2019, the Germany operations incur a loss of 1,300,000 USD. Topco, Inc. did not repatriate any current or accumulated earnings from the Germany operations in 2019. Which statement is true?

a. If Germany is a wholly owned subsidiary of Topco, Inc. and considered a CFC, Topco, Inc. reports a loss of 1,300,000 in its 2019 U.S. federal tax return.

b. If Germany is a wholly owned subsidiary of Topco, Inc. and considered a CFC, Topco, Inc. has a 1,300,000 loss in 2019 due to the Passive Foreign Investment Company regime.

c. If Germany is a wholly owned subsidiary of Topco, Inc. and considered a CFC, Topco, Inc. reports Subpart F income in its 2019 U.S. federal income tax return.

d. If Germany is a wholly owned subsidiary of Topco, Inc., treated as a disregarded foreign branch for U.S. federal income tax purposes via a U.S. Check-the-box election, Topco, Inc. reports a loss of 1,300,000 in its 2019 U.S. federal tax return.