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ForeignCorp is a Country X corporation that manufactures and sells shoes. The company has an agent in the United States who purchases raw materials (
ForeignCorp is a Country X corporation that manufactures and sells shoes. The company has an agent in the United States who purchases raw materials eg leather from US suppliers, and sends the raw materials to ForeignCorps factory in Country X for use in manufacturing shoes. ForeignCorp has a different agent in the United States who imports shoes from Country X that are manufactured by ForeignCorp in Country X plus shoes manufactured by unrelated European companies, and sells all of these shoes to US retailers. There is no tax treaty between the US and Country X
Issue : How would it affect ForeignCorps US taxability if the purchasing andor sales agent provided purchasingsales services to European shoe companies unrelated to ForeignCorp? Separately provide the relevant rules, analysis, and conclusion under the following headings:
Rule:
Analysis:
Conclusion:
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