Company A, a U.S. company, deducted costs from research and development of a product in the U.S., then licensed rights to the product to a foreign subsidiary in a lower tax jurisdiction. The subsidiary then manufactured the product and sold each unit back to Company A (the parent company). This is an example of which tax planning technique?

A. Timing of income deductions

B. Conversion of income property

C. Shifting of income

D. Deferral of income

An explanation of the answer is appreciated