Which of the following statements is true, regarding the sourcing of dividend income?

a. A percentage of dividends from non-U.S. corporations are U.S. source to the extent that 25% or more of the non-U.S. corporations gross income for the 3 years preceding the year of the dividend payment was effectively connected with the conduct of a U.S. trade or business.

b. Dividends from non-U.S. corporations are foreign-source only to the extent that 80% or more of the non-U.S. corporations gross income for the 3 years preceding the year of the dividend payment was effectively connected with the conduct of a non-U.S. trade or business.

c. Dividends are sourced based on the residence of the recipient.

d. Dividends from non-U.S. corporations are always foreign source.