what are all the specific tax considerations for the following scenario $($citing specific regulation$)$: CompCo, Inc., a corporation formed in Florida, sells laptops to US and foreign customers. CompCo, Inc. acquires some individual components of the laptops $($USB ports, keyboard keys$)$ from unrelated third$-$party suppliers in China but manufactures its laptops in Florida. CompCo, Inc. also provides tech support services to both US and foreign customers, through its team of tech nerds it calls EggHeads. These services are separately billed from the sales.

Between its manufacturing team and the EggHeads, CompCo, Inc. has a total of $$600,000$ of employee wages. Of this, $$400,000$ are related to manufacturing the laptops, which are sold worldwide. The remaining $$200,000$ of wages is for the Eggheads, who spend $40\%$ of their time traveling outside of the US to provide tech support services, and $60\%$ of their time helping customers within the US$.$

CompCo, Inc. owns its factory and warehouse that are both located in the US$.$ These real property assets are worth about $$400,000.$ The rest of CompCo, Inc.$$s trade or business assets are worth about $$600,000.$ It does not own any other assets.

Ellie is a citizen and resident of Guyana, a country with which the US does not have a tax treaty. She currently owns $20\%$ of CompCo, Inc., which she considers a great investment due to the regularity with which it issues dividends. For example, in March of $2023,$ CompCo, Inc. issued Ellie a $$30,000$ dividend. However, Ellie starts to think the tech industry is going to dip in the near future and decides to sell her interest in the company to Bonnie, a US citizen who happens to be the CEO of CompCo, Inc., for $$250,000.$

Ellie reinvests the proceeds from the sale back into the US by buying an apartment building. Ellie hires her niece and nephew, Dorie and Mac, to manage the apartment building, including collecting rent payments, paying expenses, keeping the books, and making sure the properties are maintained. Dorie and Mac are also citizens and residents of Guyana but are willing to travel move to the US to help out their aunt.

Both Dorie and Mac are very familiar with the US$,$ having spent significant amounts of time there over the last few years. For instance, Mac spent the entire previous two years $(2021$ and $2022)$ in Florida getting his MBA at FAU after finishing his undergrad degree in Guyana. While at FAU, he was in the US on his student visa but he knew he could not use that visa anymore once he started working in $2023.$ Dorie, on the other hand, spent $99$ days in $2022$ and $132$ days in $2021$ in the US between vacations and some freelance marketing work she was doing. Dorie and Mac both arrive in the US for the first time in $2023$ on August $15,2023,$ and stay through the end of the year. In addition to their salaries for managing the apartment building, both Mac and Dorie earn income from investments back home in Guyana.