• Alderson is a citizen of Canada who maintains her home in that country. She is a travelling salesperson for Canadian company. Since many of her customers are in the United States, each year she spends about 125 days out of 250 work days in the United States.

• a.) Is Alderson’s compensation, or any part of it, subject to U.S. tax?

• b.) What is the rate of tax if any?

• c.) Does the Canadian company have a U.S. withholding tax obligation? 

• d.) If Canada has income tax convention with the United States identical to the U.S. Model, how does the treaty affect the analysis?