Which of the Following Statements Best Describes the Primary Purpose

Which of the following statements best describes the primary purpose of the Subpart F income provisions?

A) They allow for a deferral of non-U.S.-source income from U.S. taxation.
B) They provide certainty as to the U.S. income tax treatment of cross-border transactions.
C) They prevent shifting of income from the U.S. to high-tax non-U.S. jurisdictions.
D) They prevent shifting of income from the U.S. to low-tax non-U.S. jurisdictions.