The Following Income of a Foreign Corporation Is Not Subject

The following income of a foreign corporation is not subject to the regular U.S.corporate income tax rates:

A) Capital gains effectively connected with a U.S. trade or business.
B) FIRPTA gains.
C) Fixed, determinable, annual or periodic income effectively connected with a U.S. trade or business.
D) Income from sale of inventory where title passes in the United States, but no U.S. trade or business exists.
E) None of the above.