Manila Corporation is organized in Country J. All of Manilas 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.parties in Count

ries J and X.

b. Manila receives a dividend from Manila-Sub, a foreign corporation organized and operating exclusively in Country J. All of Manila-Subs 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. Revend sells the product to unrelated persons in Country Z.ues from servicing this machinery outside of Country J constitute 80% of Manilas gross income.

e. Manila purchases a product from a related U.S. corporation annd sells the product to unrelated persons in Country Z.