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 from foreign corporations are always foreign source.
B) Dividends are sourced based on the residence of the recipient.
C) Dividends from foreign corporations are foreign-source only to the extent that 80% or more of the foreign corporation's gross income for the 3 years preceding the year of the dividend payment was effectively connected with the conduct of a foreign trade or business.
D) A percentage of dividends from foreign corporations are U.S.source to the extent that 25% or more of the foreign corporation's gross income for the 3 years preceding the year of the dividend payment was effectively connected with the conduct of a U.S.trade or business.