USAco, a domestic corporation, is a wholly-owned subsidiary of FORco, a foreign corporation. USAco's only assets are cash of $200,000, accounts receivable of $200,000 and its U.S. manufacturing plant worth $500,000. USAco has no liabilities. Assume that there is no intangible value in USAco and that the manufacturing plant is a USRPI. During the current year, FORco sells all of its shares of USAco to an unrelated U.S.person. Is FORco's sale of stock in USAco subject to withholding under FIRPTA? If so, how is the withholding determined?