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?

FINANCIAL ACCOUNTING
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ISBN:9781259964947
Author:Libby
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Chapter1: Financial Statements And Business Decisions
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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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