Brad is a professor at Northern Illinois University. UGH Corporation, a Mexican corporation, contracts with Brad to teach international taxation courses to its employees. Brad uses a new, really cool invention that helps students learn the material much faster than ordinary, boring professors. As a result, Brad only spends $10$ hours teaching in Mexico. Most regular, boring professors would spend $100$ hours in Mexico teaching the same material.

Please assume that Mexico and the US have a tax treaty that is identical to the US Model Treaty.

Brad earns $$1,000,000$ from his work in Mexico. Hacienda, the Mexican Internal Revenue Service, deems the payments to Brad as income from personal services and state that Brad has permanent establishment in Mexico. As a result, they assess withholding on Brad at $30\%,$ and Brad receives a check for $$700,000($which is net of the withholding of $30\%).$

The United States deems the payment to be $90\%$ royalty income and $10\%$ as income from personal services in Mexico. The US does believe that Brad had permanent establishment in Mexico, but only to the extent of his services. How much of the income that Brad earned in Mexico will be considered as US source income by the United States?