1.Assume a US taxpayer develops computer software in the US and then sells the rights to the software to a French corporation, which will use the software in France. As payment for the sale, the French corporation pays the US corporation $1 million, which is not contingent on use of or any revenue generated by the copyright. The revenue/gain from the sale is

a.US source income

b.French source income

c.50% US source income and 50% French source income

d.Neither US source income nor French source income

2.Assume a French corporation sells a patent to another French corporation for $10 million. The patent will be used in France. The seller has a basis in the patent of $4 million. The patent had previously been used by the seller in the US and a total of $1 million of amortization had been deducted by the seller on its US tax returns. How much, if any, of the gain is US source income?

a.0

b.$6 million

c.$1 million

d.$2 million

3.Assume a US taxpayer develops computer software in the US and then sells the rights to the software to a French corporation, which will use the software in France. As payment for the sale, the French corporation will pay the US corporation 10% of the revenue that is generated from the sue of the copyright for a 10 year period. $ The revenue/gain from the sale is:

a.US source income

b.French source income

c.50% US source income and 50% French source income

d.Neither US source income nor French source income