USAco, a domestic corporation, forms a business entity called a private limited company in country F. Under country F law, such entities are not subject to country F's corporate income tax, but do provide limited liability to their owners. USAco never makes a U.S. check-the-box election with respect to the country F private limited company. For U.S. tax purposes, the private limited company is treated as:

a corporation.

a branch.

a branch because it is not subject to country F's corporate income tax.

neither a branch nor a corporation.