gem 0 g,qq 30 0 AI 5g 10g 10g 10g 10g 30 0 d,t 30 30 30 30 30 30 30 No U.S. tax is imposed on a percentage of any dividend paid by a U.S. Corporation that received at least 80% of its gross income from an active foreign business for the 3-year period before the dividend is declared. (see section