Definition of Foreign Base Company Income. Manila Corporation is organized in

Country J. All of Manila's stock is owned by Simpson, a U.S. corporation. 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 dividend from Manila-Sub, a foreign corporation 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 corporation.

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. corporation and sells the product to

unrelated persons in Country Z.