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Dividends are sourced where the payor corporation is incorporated. Generally, dividends received from a domestic corporation are U.S. source income and dividends received from a foreign corporation are foreign source income. Dividends from a foreign corporation will be treated in part as U.S. source income if, during the preceding three taxable years, 25 percent or more of the corporation’s gross income from all sources was effectively connected with the conduct of a U.S. trade or business. See Page 8