Section 1248 Applies to Which of the Following Transactions

Section 1248 applies to which of the following transactions?

A) Sale or exchange of stock in a U.S.corporation by a foreign person.
B) Sale or exchange of stock in a U.S.corporation by a U.S.person.
C) Sale or exchange of stock in a controlled foreign corporation by its 100% U.S.shareholder.
D) Sale or exchange of stock in a foreign corporation that has never been a controlled foreign corporation by a U.S.person.
E) None of the above transactions is affected by § 1248.