Level 15

If your client was in the US for very brief periods, depending on whether he/she was from a treaty country, the number of days spent in the US for any purpose (either during the calendar year or a 12-month period), the amount of income earned, how the cost of his/her remuneration was borne, and whether the employer has a PE in the US, it is possible that treaty exemption or §861(a)(3) may apply.

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