Jimmy Johnson, a U.S. citizen, is employed by General Motors Corporation, a U.S. corporation. In June 2019, General Motors relocated Jimmy to its operations in Germany for the remainder of 2019. Jimmy was paid a salary of $250,000. As part of his compensation package for moving to Germany, Jimmy received a cost of living allowance of $30,000, which was paid to him only while he worked in Germany. Jimmy's salary was earned ratably over the 12-month period. During 2019 Jimmy worked 260 days, 130 of which were in Germany and 130 of which were in the United States. How much of Jimmy's total compensation is treated as foreign source income for 2019?
What will be an ideal response?
$155,000.
Jimmy apportions 50 percent (130/260) of his $250,000 salary to foreign source income (50% × $250,000 = $125,000). His cost of living allowance of $30,000 is treated as foreign source income because it is considered a fringe benefit that is sourced based on a geographic basis.
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