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USAco, a domestic corporation, manufactures and sells widgets in the United States. To market its widgets in Europe, USAco forms CAYco, a Cayman Islands corporation.
USAco, a domestic corporation, manufactures and sells widgets in the United States. To market its widgets in Europe, USAco forms CAYco, a Cayman Islands corporation. The Cayman Islands does not have a corporate income tax. USAco sells widgets at arm's length to CAYco, which exports the widgets to Europe. The income of CAYco is:
a foreign base company sales income.
b foreign personal holding company income.
c foreign base company oil-related income.
d foreign base company services income.
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