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During Year 4, Charlie, an NRA, receives interest income of $50,000 from PJ, Inc., an unrelated U.S. corporation. Considering the following facts related to PJs

  1. During Year 4, Charlie, an NRA, receives interest income of $50,000 from PJ, Inc., an unrelated U.S. corporation. Considering the following facts related to PJ’s operations, what is the sourcing of the interest income received by Charlie

Year

U.S.-source

income

Active foreign

business income

Total gross

income

Year 1

$200,000

$ 500,000

$ 700,000

Year 2

50,000

950,000

1,000,000

Year 3

100,000

900,000

1,000,000

Totals

$350,000

$2,350,000

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