Which of the following statements regarding the sourcing of dividend income is true?
A) Dividends are sourced based on the residence of the recipient.
B) Dividends from non-U.S. corporations are always foreign source.
C) Dividends from non-U.S. corporations are foreign-source only to the extent that 80% or more of the non-U.S. corporation's gross income for the three years preceding the year of the dividend payment was effectively connected with the conduct of a non-U.S. trade or business.
D) A percentage of dividends from non-U.S. corporations are U.S. source to the extent that 25% or more of the non-U.S. corporation's gross income for the three years preceding the year of the dividend payment was effectively connected with the conduct of a U.S. trade or business.
Correct Answer:
Verified
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