US-Cco is a United States C Corporation that is wholly owned by FRGNco, a company incorporated in country F, which has a tax treaty with the United States like the United States Model Treaty. FRGNco is privatelyowned by six unrelated residents of Canada. FRGNco manufactures widgets and earns $500,000 of income, all from the sale of those widgets to US-Cco. US-Cco owns valuable marketing intangibles, which make its resale of the widgets extremely profitable. During the