which of the following statements best describes the operation of subpart F as it applies to income earned by a foreign corporation?

A. Subpart F causes all income of a controlled foreign corporation to be treated as a deemed dividend to all U.S. persons owning stock in the corporation on the last day of the corporation's tax year.

B. Subpart F causes certain income of a controlled foreign corporation to be treated as deemed dividend to all U.S. persons owning stock in the corporation on the last day of the corporation's tax year.

C. Subpart F causes certain income of a controlled foreign corporation to be treated as deemed dividend to only those U.S. shareholders owning stock in the corporation on the last day of the corporation's tax year.

D. Subpart F causes all income of a controlled foreign corporation to be treated as a deemed dividend to only those U.S. shareholders owning stock in the corporation on the last day of the corporation's tax year.