In order to qualify for the favorable tax treatment of a Foreign Sales Corporation, a U.S. firm must meet all of the following tests, except: a. at least one director must be a nonresident of the U.S. b. its income must be derived from qualified export activity such as the sale of goods abroad. c. management must be outside the U.S. d. none of the income may be repatriated to the United States. e. the FSC must participate in soliciting, negotiating, or contracting with a foreign buyer.