Manila Corporation is organized in Country J. All of Manila's stock is owned by Simpson, a U.S.

Question:

Manila is organized in Country J. All of Manila's stock is owned by Simpson, a U.S. Indicate which of the following transactions generate Subpart F income.
a. Manila purchases a product from Simpson and sells it to unrelated parties in Countries J and X.
b. Manila receives a from Manila-Sub, a foreign organized and operating exclusively in Country J. All of Manila-Sub's stock has been owned by Manila since its incorporation.
c. Manila purchases raw materials locally, manufactures products in Country J, and sells the products to an unrelated purchaser for use in Country Z.
d. Manila services machinery manufactured by an unrelated Country J Revenues from servicing this machinery outside of Country J constitute 80% of Manila's gross income.
e. Manila purchases a product from a related U.S. and sells the product to unrelated persons in Country Z?
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