1. federal income tax on the gain recognized on the sale of stock in subsidiaries that are not USRPHCs, unless X were an investment company. See supra Part II.A.4.b.(4). In addition, since X would have terminated its U.S. trade or business, X would not be liable for branch profits tax with respect to the year of the termination. See Temp;U S;These rates can reach as high as 35%. X would not, however, be liable for