A U.S. business conducts international communications activities between the U.S. and Spain. The resulting income is sourced 100% to the U. S., the residence of the taxpayer.

Question

Quizplus · Accepted Answer

If the communications activities are carried out between the U.S. and Spain, and the income is generated from Spain, then a portion of the income should be sourced to Spain. Therefore, the resulting income may not be sourced 100% to the U.S., but may be subject to taxation in both countries under certain circumstances.

A US Business Conducts International Communications Activities Between the U