Faye was a worldrenowned rock star from ABCCountry A record company located in the USA named PlatinumUSA Records contracted with Faye to produce records PlatinumUSA Records retained all intellectual property rights in the recordings The contract granted Faye payments or royalties based upon future sales of recordings Faye paid taxes on the payments in ABCCountry as royalties A treaty between the USA and ABCCountry exempts royalties from tax in the USA However the treaty did not define royalties