Cecilia, a Brazilian citizen and resident, spent 120 days working in the United States in the current year and earned $50,000. Because she spent more than 90 days in the United States, Cecilia's income will be treated as U.S. source and subject to U.S. taxation. The United States does not have an income tax treaty with Brazil.

Question

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Cecilia's income will be treated as U.S. source and subject to U.S. taxation because she spent more than 90 days in the United States. The United States not having an income tax treaty with Brazil means that there is no agreement in place to avoid double taxation of income.

Cecilia, a Brazilian Citizen and Resident, Spent 120 Days Working