Serena, a nonresident alien, is employed by GlobalCo, a non-U.S. corporation. She works in the United States for three days during the year, receiving a gross salary of $2,500 for this period. GlobalCo is not engaged in a U.S. trade or business. Under the commercial traveler exception, the $2,500 is not classified as U.S.-source income.

Question

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The commercial traveler exception allows nonresident aliens to exclude income earned for services performed in the U.S. if they are present for 90 days or less, earn less than $3,000, and are employed by a foreign employer not engaged in U.S. trade or business.

Serena, a Nonresident Alien, Is Employed by GlobalCo, a Non-U