USAco, a domestic corporation, has owned 100% of the stock of FORco, a foreign corporation, since FORco was organized 10 years ago. USAco's basis in the stock is $100,000. FORco has earnings and profits of $500,000. USAco sells FORcos's stock to an unrelated party for $1,000,000. The tax effect of the transaction is:

(a) USAco has a dividend of $900,000

(b) USAco has capital gain of $900,000

(c) USAco does not have to report any income from the transaction

(d) USAco has a capital gain of $400,000 and a dividend of $500,000