Question: 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

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 $1million, which is not contingent on use of or any revenue generated by the copyright. The revenue/gain from the sale is US source income French source income 50% US sounce income and 50% French source income Nenther US source incorne nor French source incame

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