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ForCo, a foreign corporation, lends $100,000 to Toni, a U.S. citizen. Interest of $10,000 is payable annually on December 31 of each year. Toni is

ForCo, a foreign corporation, lends $100,000 to Toni, a U.S. citizen. Interest of $10,000 is payable annually on December 31 of each year. Toni is physically present in Mexico on December 31, 2019 when he pays the interest. The source of the interest income is U.S.-source because Toni is a U.S. resident

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