Fabio, a citizen and resident of Paraguay, is a professional model. Last summer, Fabio posed in front of the Washington Monument for the cover of a forthcoming romance novel to be published exclusively in Paraguay by a Paraguayan publisher that is not engaged in a trade or business within the United States. The photo shoot took only a single day and Fabio received total compensation of $2,000 under a contract with a US modeling company which performed the photo shoot on behalf of the Paraguayan publisher.

Group of answer choices

A-Fabio owes no US tax.

B-Fabio owes US tax at the regular Code sec 1 rates.

C-Fabio owes US tax at a 30% rate under Code sec 871(a).

D-The US modeling company does not have to withhold under Code sec 1441 on the payment.