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Hermann, an individual who is a Country Y citizen and resident, and nonresident alien, acquires Patent X from an unrelated person. Hermann is not engaged
Hermann, an individual who is a Country Y citizen and resident, and nonresident alien, acquires Patent X from an unrelated person. Hermann is not engaged in any trade or business. Hermann then sells all of the US rights in Patent X to DomesticCo, a US corporation. DomesticCo will use the patent in the United States to produce and sell Product X only to US customers. The price paid to Hermann is based solely on the US sales of Product X No tax treaty applies to this transaction.
Issue: In what country will the income from the sale of Patent X be sourced?
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