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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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