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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?
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