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Sting, a nonresident alien individual, is interested in performing a rock concert in Chicago. A promoter in the United States (Promoter), organized as a U.S.

Sting, a nonresident alien individual, is interested in performing a rock concert in Chicago. A promoter in the United States ("Promoter"), organized as a U.S. corporation, has agreed to pay $1,000,000 to Sting to perform in the U.S. Sting incurs $400,000 in expenses in connection with the concert performance. Assume no treaty benefits are available to Sting. Which one of the following statements best describes the U.S. tax obligations of Promoter?

a. Promoter must withhold $370,000 on the effectively connected income earned by Sting.

b. Promoter must withhold $300,000 on the fixed, determinable, annual, or periodic income paid to Sting.

c. Promoter does not have any withholding obligation on the fixed, determinable, annual, or periodic income paid to Sting.

d. All of the above. e. None of the above.

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