id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-444	Tillinghast, David R.	Taxation of Electronic Commerce: Federal Income Tax Issues in the Establishment of a Software Operation in a Tax Haven	2022	41	.pdf	application/pdf	17927	974	62	The court stated: In order for [the Hong Kong corporation] to be considered as having U.S. source income by virtue of the performance of services, [the corporation] itself would have to perform the services through agents or employees of its own. 87 It is difficult to know exactly what to make of the quoted statement. Accordingly, even in the absence of an applicable income tax treaty, Softco would appear to be exposed to U.S. corporate income tax only in this last situation.	cache/ftr-444.pdf	txt/ftr-444.txt