During the current year, Bailey, a U.S. corporation, began operating overseas. It manufactures machine tools in the United States and sells them to Canadian customers through a branch office located in Toronto. Bailey acquired a 40% investment in a Brazilian corporation from which it later received a dividend. The company received royalties from an English firm that licences machine tool patents owned by Bailey. The English firm uses the patents to manufacture machine tools that the firm sells in England. What international tax issues regarding these activities should Baileys director of taxes consider?