The Midori Bank, not a U S person, paid a dividend this year to Rhoda, a U S citizen What is the proper sourcing of the dividend income Be specific ...

Dividends paid by a foreign corporation may be partially USsource income ...

The Midori Bank, not a U.S. person, paid a dividend this year to Rhoda, a U.S. citizen.

Question:

The Midori Bank, not a U.S. person, paid a this year to Rhoda, a U.S. citizen. What is the proper sourcing of the income? Be specific.
Dividend
A dividend is a distribution of a portion of company’s earnings, decided and managed by the company’s board of directors, and paid to the shareholders. Dividends are given on the shares. It is a token reward paid to the shareholders for their...