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Chang, a nonresident alien, is employed by Fisher, Inc., a foreign corporation. Chang spent a considerable period of time during 2017 in the U.S. performing

Chang, a nonresident alien, is employed by Fisher, Inc., a foreign corporation. Chang spent a considerable period of time during 2017 in the U.S. performing consulting services for Fishers U.S. branch, which operates a factory in Los Angeles. The commercial traveler exception will exempt Changs compensation from being sourced to the U.S.:

a. If she was in the U.S. for 90 days or less.

b. If the amount paid to her for the period she was in the U.S. is less than $3,000.

c. If she is an independent contractor.

d. If (a) and (b) are true, and (c) is not true.

e. The commercial traveler exception cannot apply because her employer is engaged in a trade or business in the U.S.

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