The dividend will be qualified if the foreign corporation is a qualified by itself... per the IRS: A foreign corporation is a qualified foreign corporation if it meets any of the following conditions.
*The corporation is incorporated in a U.S. possession.
*The corporation is eligible for the benefits of a comprehensive income tax treaty with the United States that the Treasury Department determines is satisfactory for this purpose and that includes an exchange of information program. For a list of those treaties, see Table 8-1.
*The corporation does not meet (1) or (2) above, but the stock for which the dividend is paid is readily tradable on an established securities market in the United States. <a rel="nofollow" target="_blank" href="
https://www.irs.gov/publications/p17/ch08.html">https://www.irs.gov/publications/p17/ch08.html</a> - the link also lists nonqualified dividends.
