Client received $120,000 of dividend income in 2015 from EUCO. EUCO is a foreign corporation that earned the following income during the period 2012-2015:
|
Year
|
Worldwide Gross Income
|
Income Effectively Connected w/ U.S. Trade or Business
|
|
2012
|
$250,000
|
$100,000
|
|
2013
|
$500,000
|
$150,000
|
|
2014
|
$550,000
|
$220,000
|
|
2015
|
$600,000
|
$385,000
|
What portion of the dividend will be classified as U.S.-source gross income?