Calabra, S.A., a Peruvian corporation, manufactures inventory in Peru. The inventory is sold to independent distributors in the United States; title passes to the purchaser in the United States. Calabra has no employees or operations within the United States. All sales activities are conducted via telephone and internet communication between Calabra's home office and its U.S. customers. Does Calabra incur any income effectively connected with a U.S. trade or business? Earning U.S.-source income does create a trade or business presence in the United States. Therefore, Calabra has income effectively connected with a U.S. trade or business