9) Bearing, Inc., a corporation organized in the U.S., owns 100% of the stock of Bearing Espana S.A., a corporation organized in Spain, and Bearing Tools BV, a corporation organized in the Netherlands. Bearing, Inc. manufactures industrial tools and parts for sale to customers in the U.S. and Europe. Sales to customers in Spain are made through Bearing Espana S.A., a marketing subsidiary. Sales to customers in France, Germany and Poland are made by Bearing Tools BV, a limited risk distributor of Bearing, Inc. products. Bearing Tools BV does not perform any functions with respect to the manufacture or sale of Bearing, Inc. products. Which one of the following statements is true?

a. Bearing Tools BV gross profits from the sale of product is Foreign Base Company Sales Income

b. Bearing Espana S.A. and Bearing Tools BV are not controlled foreign corporations

c. Bearing Espana S.A. gross profits from the sale of product is Foreign Personal Holdings Company Income

d. Bearing Tools BV activity meets the Substantial Contribution requirements to be eligible for the FBCSI manufacturing exception