1. USAco is a wholly-owned U.S. subsidiary of FORco, a foreign corporation. USAcos anoky assets held by the U.S. corporation are Cash of $400,000, Accounts Receivable of $400,000 and USAcos U.S. manufacturing plant and related property with a fair market value of $1 million. FORco, the owner of USAcos stock, sells the stock of USAco to a Buyer for cash consideration equal to the fair market value of the assets of USAco. Which one of the following best describes the important tax implication for the sale transaction?
   1. The Buyer is required to withhold $180,000 of the purchase price for payment to the IRS
   2. USAco cannot deduct any interest expense that it pays
   3. The Buyer must withhold $270,000 of the purchase price under FIRPTA for payment to the IRS
   4. The Buyer is not required to withhold $180,000 of the purchase price for payment to the IRS.