In 2021, Rodrigo sold the 1,000 shares for $200 per share. What is the U.S. tax consequence to Rodrigo on the sale of the shares in in Super Technologies?

a) The $100,000 of capital gain is subject to U.S. net income tax because the gain is from a trading business in the U.S.

e) The $100,000 of capital gain is subject to gross U.S. withholding tax at 30% because the gain is from shares of a U.S. corporation

b) No U.S. tax because the gain is qualified dividend income

c) No U.S. tax because the gain is from trading a security for Rodrigo's own account