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.
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