ForeignCorp is a Country X corporation that sells software. There is no tax treaty between the United States and Country X$.$ ForeignCorp sells the software through a website operated in Country X$.$ A substantial amount of ForeignCorp$$s income is earned from U$.$S$.$ customers, and results in U$.$S$.-$sourced income. In $2018,$ ForeignCorp sends a number of its employees to the United States to assist its business clients with the installation and configuration of its software on their U$.$S$.$ computers.

Assume that the presence of its employees in the United States causes ForeignCorp to be engaged in the conduct of a U$.$S$.$ trade or business. One of its employees, Humbert, a Country X citizen and resident, spends a total of $140$ days in the United States during $2018($assume Humbert is not considered a resident alien$).$

Humbert is paid a salary of $$100,000$ by ForeignCorp for $2018.$ In addition, ForeignCorp reimburses Humbert $$75,000$ for travel, meals, and lodging expenses incurred in the United States. In addition, ForeignCorp provides Humbert with the following benefits during $2018,$ none of which are directly related to his work in the United States: reimbursement of education costs $($$$5,000),$ medical benefits $($$$20,000),$ and pension benefits $($$$10,000).$

$1.$ What are the implications of these facts for ForeignCorp$$s effectively connected income in $2018?$

$2.$ What are the implications of these facts for Humbert$$s taxability in the United States in $2018?$

$3.$ What are the implications to ForeignCorp and to Humbert of the amounts paid to and on behalf of Humbert during $2018?$