Which of the Following Statements Regarding the Sourcing of Dividend

Multiple Choice

Which of the following statements regarding the sourcing of dividend income is true?

A) Dividends are sourced based on the residence of the recipient.
B) Dividends from a U.S. corporation are U.S.-source based on the percentage of U.S.-source income earned by the U.S. payor.
C) Dividends from a U.S. corporation are U.S. source without regard to where the U.S. corporation generated the E & P.
D) Dividends from a U.S. corporation are foreign-source based on the percentage of foreign-source income earned by the U.S. payor.