Which of the Following Transactions by a U

Multiple Choice

Which of the following transactions by a U.S.corporation may result in taxation under § 367.

A) Incorporation of U.S branch as a U.S.corporation when the branch earns foreign-source income.
B) Incorporation of a U.S.branch as a U.S.corporation if the new U.S.corporation has no foreign shareholders.
C) Incorporation of a U.S.branch as a U.S.corporation if the new U.S.corporation also has foreign shareholders.
D) All the above.
E) None of the above.