1. Carlson, a citizen and resident of Denmark, is a commodities dealer operating in Copenhagen. During the tax year, Carlson, by e-mail from her home office, purchased several carloads of wheat. She took title to the wheat in Minneapolis. The wheat was sold to the government of India, FOB New York City, where the wheat was placed aboard a Liberian flag vessel. Carlson has never been to the United States. While she has occasionally purchased U.S. commodities in the past, this is her sole transaction in the United States during the current year. Does she have any potential U.S. income tax liability? 5. Rosario, a corporation organized in Argentina, sells consumer products to retailers in the main cities of that country. Rosario has no office in the United States.

2. Rosario sales representatives in Argentina send orders to a purchasing agent in New York. The purchasing agent purchases the products from U.S. manufacturers in Rosarios name. The products are shipped to Miami and delivered to vessels bound for Argentina. Orders are accepted in Argentina. Title to the goods is transferred to customers at the port of destination. However, the customers have agreed contractually to insure against all losses attributable to shipwreck, fire and accident while the goods are in transit. The Argentine customers make payment to an account maintained by Rosario in Switzerland. Does Rosario have any liability for U.S. taxes? Would your answer differ if the purchasing agent is properly characterized as an independent agent?