Sloop, Inc., a foreign corporation, sells wireless devices in several countries, including the United States. In fact,

Question:

Sloop, Inc., a foreign corporation, sells wireless devices in several countries, including the United States. In fact, currently 25% of Sloop's sales income is sourced in the United States (through branches in New York and Chicago). Sloop is considering opening additional branches in San Diego and Denver to increase U.S. sales. What tax issues must Sloop consider before making this move?