A foreign company (FC), located in Country X, treated as a corporation for U.S. tax purposes, purchases and sells products within and outside the U.S. For U.S. sales, the employees of FC travel from Country X into U.S. (the customer's country of location) to discuss, negotiate and sign sales contracts. For U.S. sales, FC's employees stay at a hotel and meet with customers at the customer's office. The process is the same for non-US customers. Discuss whether FC is subject to U.S. taxation under section 882(a) of the IRC assuming (a) an income tax treaty did not apply and, alternatively (b) an income tax treaty similar to the U.S. model income tax treaty applied