P is an orchestra conductor and a nonresident alien who contracted with C to make recordings of orchestral works. The contract provides that all recordings are the property of which will pay P based on the percentage of its sales receipts. Assume the recording is done in the U.S. but the recordings are sold all over the world. Is P subject to U.S. tax on its income? If you were P's tax adviser, how could you have restructured the arrangement to limit or avoid U.S. tax? (15 points)