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Galaxy, a U.S. corporation engaged in the engineering business, performed services under a contract with a Canadian corporation. The employee of Galaxy who performed the

Galaxy, a U.S. corporation engaged in the engineering business, performed services under a contract with a Canadian corporation. The employee of Galaxy who performed the services spent 25 working days in Canada and 50 working days in the United States. Because the work in the United States was largely routine supervision of drafting of plans while the work in Canada demanded a high degree of creativity and presence above the Artic Circle, Galaxy charged $50,000 for the work in Canada and $50,000 for the work in the United States. Assume that Galaxy would like to maximize the amount of income treated as foreign-source because the income will be exempt from Canadian tax, and Galaxy has other income that generates excess foreign tax credits. How much of the gross income for services can Galaxy treat as foreign-source gross income?

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