Liang, an NRA, is sent to the United States by Fuller Corporation, her foreign employer. She spends 50 days in the United States and earns $20,000 for a two-month period. This amount is attributable to 40 U.S. working days and 10 non-U.S. working days. Her employer does not have a U.S. trade or business and Liang spends no other time in the U.S. for the tax year. Liang's U.S.-source taxable
income is:
a. $20,000.
b. $16,000.
c. $3,000.
d. $0.
b
RATIONALE: Liang does not meet the commercial traveler exception. She was in the United States for 90 days or less during the year, she was working for a foreign employer that did not have a U.S. trade or business, but she earned more than $3,000 [$16,000 ($20,000 × 40/50)] for the days worked in the United States.
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What will be an ideal response?