Your client is a US citizen. She is going to open an export business selling purchased inventory in a foreign country that has a tax treaty with the US. She is not sure whether she will sell to the foreign country through an agent or through having her own employees and an office in the foreign country. Write a memo on the tax consequences and include tax planning advice that you think important to mention under the two scenarios.

Basically you want your memo to convince me that you know the tax areas/issues that need to be discussed with the client even if your memo cannot definitively say for sure a tax result since choices may exist on how to structure the transactions. Let me know that you understand what those choices might be and the consequences of those choices.