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 non-U.S. corporations are always foreign source.
C) Dividends from non-U.S. corporations are foreign-source only to the extent that 80% or more of the non-U.S. corporation's gross income for the three years preceding the year of the dividend payment was effectively connected with the conduct of a non-U.S. trade or business.
D) A percentage of dividends from non-U.S. corporations are U.S. source to the extent that 25% or more of the non-U.S. corporation's gross income for the three years preceding the year of the dividend payment was effectively connected with the conduct of a U.S. trade or business.