Please expiain the relauonslip e Concepts ol 5Udk-up tax an "subsidies" to the foreign tax credit. (10 points) 8. T, a U.S. corporation is a franchiser of "Mister Donut" shops. In an asset transaction, T sold its Japanese intangible rights to a Japanese buyer These rights were directly held by T. None of the assets had been depreciated for tax purposes by T. The payment for these rights was made in a lump-sum. If you were T's tax advisor, under what theory would you argue that the income from the disposition is foreign source? How should a court decide this issue? Is there any other way of structuring the transaction to generate foreign source income? (10 points)