ChоcIndy Inc. is аn internаtiоnаl chоcolate manufacturer headquartered in Berne, Indiana. The company, a U.S. taxpayer, has several investments in foreign entities with the following information for the current fiscal year period: Entity/Branch Country Percent owned Activity Income before Tax ($ millions) Income Tax Rate Dividend Withholding Tax Net Dividend Received by Parent ($ millions) ChocIndy Inc. USA Parent Manufacturing $25 21% -- -- ChocSwiss AG Switzerland 100% Distribution $ 5 12% 5% $0.95 ChocBrasil Filial Brazil 100% Manufacturing/Sourcing $7 24% 0% $0.00 ChocPRC Corp. China 51% Manufacturing $10 25% 10% $0.00 Additional Information: 1. ChocIndy Inc.'s $25 million income before tax is derived from the production and sale of products in the United States. 2. Each entity is legally incorporated in its host country other than ChocBrasil Filial, which is registered with Brazil's government as a branch. 3. ChocSwiss AG sells the chocolates purchased from ChocIndy Inc., 97% of the ChocSwiss AG's sales are made in France, Italy, Germany, Austria and Slovenia. The remaining 3% of sales are made in Switzerland. 4. ChocIndy Inc., ChocBrasil Filial and ChocPRC Corp. produce and market the chocolates in their home countries. Is the foreign source income generated by the entity in Switzerland taxable in the U.S?