Erica is a citizen of a foreign country and works as an employee for Fco, a foreign corporation that manufactures industrial equipment. Fco does not have a permanent establishment in the United States. Erica’s job is to provide technical assistance to customers who purchase Fco’s products. Many of Erica’s customers are located in the United States. Consequently, Erica consistently spends about 120 working days per year in the United States. Erica does not possess a green card. Assume that the United States has entered into an income tax treaty with Erica’s home country that is identical to the United States Model Income Tax Convention of 2016. How does the United States tax Erica’s activities?
Erica is a citizen of a foreign country and works as an employee for Fco, a foreign corporation that manufactures industrial equipment. Fco does not have a permanent establishment in the United States. Erica’s job is to provide technical assistance to customers who purchase Fco’s products. Many of Erica’s customers are located in the United States. Consequently, Erica consistently spends about 120 working days per year in the United States. Erica does not possess a green card. Assume that the United States has entered into an income tax treaty with Erica’s home country that is identical to the United States Model Income Tax Convention of 2016. How does the United States tax Erica’s activities?
Chapter3: Tax Formula And Tax Determination : An Overview Of Property Transactions
Section: Chapter Questions
Problem 13DQ
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Erica is a citizen of a foreign country and works as an employee for Fco, a foreign corporation that manufactures industrial equipment. Fco does not have a permanent establishment in the United States. Erica’s job is to provide technical assistance to customers who purchase Fco’s products. Many of Erica’s customers are located in the United States. Consequently, Erica consistently spends about 120 working days per year in the United States. Erica does not possess a green card. Assume that the United States has entered into an income tax treaty with Erica’s home country that is identical to the United States Model Income Tax Convention of 2016.
How does the United States tax Erica’s activities?
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