Determine whether income is U$.$S$.-$ or foreign$-$sourced.

Apply the U$.$S$.$ tax provisions concerning nonresident alien individuals and foreign corporations. Determine whether the sourcing of income in each of the following situations is U$.$S$.$ or foreign.

a$.$USCo sells depreciable personal property $($produced in the United States$)$ that it has been using in its foreign branch operations. The property sells for $$180,000,$ has a tax basis of $$75,000,$ and has been depreciated for tax purposes to the extent of $$90,000.$ The property is located in a foreign country but is sold to another domestic corporation. The sales transaction takes place in the United States.

b$.$ Jacques, an NRA, sells an apartment building to Julie, a U$.$S$.$ resident, at a $$200,000$ gain. The building is located in Denver. The closing takes place in Jacques$$s country of residence.

c$.$ Carla, an NRA, is an employee of a non$-$U$.$S$.$ corporation. During the tax year, she spends $80$ days in the United States purchasing cloth for her employer, a clothing manufacturer. Her yearly salary is $$150,000($translated into U$.$S$.$ dollars$).$ Carla spends a total of $200$ days working during the year. Her employer has no other business contacts with the United States.

d$.$ Development, Inc., a U$.$S$.$ corporation, earns $$1,100,000$ in royalty income from Far East, Ltd$.,$ a foreign corporation, for the use of several patented processes in Far East$$s manufacturing business located in Singapore.