The US Internal Revenue Code Contains Many Provisions That Limit the the Ability

The U.S. Internal Revenue Code contains many provisions that limit the ability of individuals and corporations to defer the payment of taxes on foreign-source income. One of the most significant of these provisions is that restrictions are placed on controlled foreign corporations (CFCs) , and in particular on "Subpart F income." Which of the following statements about subpart F income is/are incorrect?

A) Subpart F income is income that is easily shifted from one foreign location to another or has little or no economic connection to the CFC's country of origin.
B) Passive income, such as interest or dividends earned by owning financial securities, and rents and royalties from intangible property, is always considered to be subpart F income.
C) Sales income, whether either production of the goods or the final customers to whom they are sold are located in the CFC's home country and neither the supplier of the goods nor the customer is related to the CFC, is always considered to be subpart F income.
D) All of the statements above are correct.
E) Both statements b and c are incorrect.