A U.S. manufacturer wants to conduct business through a foreign subsidiary organized in a low tax jurisdiction. How might it do so without being currently taxed on the subsidiarys foreign earnings?

If the subsidiary purchases goods or commodities produced in the low tax jurisdiction, and then sells them to the U.S. parent at an arms length price, then the subsidiarys sales income will not be currently taxed tot eh U.S. parent under Subpart F or Sec. 482.

If the subsidiarys sales are confined to markets within the low tax jurisdiction, then the subsidiarys sales income will not be currently taxed to the U.S. parent under Subpart F.

If the subsidiarys manufacturing operations contribute to at least 20% of the cost of the goods sold, the subsidiarys operating income will not be currently taxed to the U.S. parent under Subpart F.

All of the above.