ACC – Erica is a citizen of a foreign country
Erica is a citizen of a foreign country, and is employed by a foreign-based computer manufacturer. Ericaâs job is to provide technical assistance to customers who purchase the companyâs mainframe computers. Many of Ericaâs customers are located in the United States. As a consequence, Erica consistently spends about 100 working days per year in the United States. In addition, Erica spends about 20 vacation days per year in Las Vegas, since she loves to gamble and also enjoys the desert climate. Erica does not possess a green card. Assume that the United States has entered into an income tax treaty with Ericaâs home country that is identical to the United States Model Income Tax Convention of November 15, 2006.How does the United States tax Ericaâs activities? How would your answer change if Erica were a self-employed technician rather than an employee?
