Carmen SanDiego, a U.S. citizen, is employed by General Motors Corporation, a U.S. corporation. On April 1, 2019, GM relocated Carmen to its Brazilian operations for the remainder of 2019. Carmen was paid a salary of $120,000 and was employed on a 5-day week basis. As part of her compensation package for moving to Brazil, Carmen also received a housing allowance of $25,000. Carmen’s salary was earned ratably over the 12-month period.

During 2019 Carmen worked 260 days, 195 of which were in Brazil and 65 of which were in Michigan.

How much of Carmen’s total compensation is treated as foreign source income for 2019? Why might Carmen want to maximize her foreign source income in 2019?