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.
Answer: C
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