Which of the following transactions by a U.S.corporation may result in taxation under § 367?
A) Incorporation of U.S branch as a U.S.corporation when the branch earns only foreign-source income.
B) Incorporation of a U.S.branch by a U.S.corporation when the branch earns only U.S.-source income.
C) Incorporation of a U.S.branch as a U.S.corporation if the new U.S.corporation also has foreign shareholders.
D) Incorporation of a U.S.branch as a U.S.corporation if the new U.S.corporation has no foreign shareholders.
Correct Answer:
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