Janna is a United States citizen. On January $1$ of Year $1,$ Janna, who annually is in the $24\%$ tax bracket, pays $$500$ for one of the $100$ outstanding shares in Taiwan Equities $("$TE$"),$ a Taiwan corporation that invests in Asian entities not incorporated in Taiwan. Assume that the appropriate rate of interest on any amount 

a$.$ In Year $1,$ TE earns $$100,000.$ When preparing her return for Year $1,$ Janna files a Form $8621$ that elects Qualified Electing Fund $("$QEF$")$ status. What are the U$.$S$.$ tax implications to Janna?

b$.$ Assume that in the following year, which is Year $2,$ TE again earns $$100,000.$ On December $31$ of Year $2,$ TE distributes $$2,000$ to Janna. What are the U$.$S$.$ tax implications to Janna?

c$.$ Continue to assume that TE earns $$100,000$ in Year $1$ and $$100,000$ in Year $2,$ but that Janna never makes a QEF election. Moreover, on December $31$ of Year $2,$ without having received a dividend, Janna sells her TE share for $$2,500.$ What are the United States tax implications to Janna?