Which of the Following Statements Is True, Concerning the Sourcing

Multiple Choice

Which of the following statements is true, concerning the sourcing of income from inventory produced by the taxpayer in the U.S. and sold outside the U.S.?

A) Because the inventory is manufactured in the U.S., all of the inventory income is U.S. source.
B) If title passes on the inventory outside the U.S., all of the inventory income is foreign source.
C) The taxpayer may source one-half the income based on title passage and one-half the income based on where the sale negotiation takes place.
D) The taxpayer may source one-half the income based on title passage and one-half the income based on location of production assets.