US International Taxation:
Three of the leading medical practitioners in Las Vegas, Nevada, are Jackson, Martinez, and Agnew. Each has a medical practice, is a sole practitioner, and is a United States citizen.
In year 1, Jackson conducted a medical practice in las vegas earning $850,000 and also acted as an expert witness and consultant for a Canadian client in class action litigation taking place in Montreal. Throughout year 1, he commuted to and from Canada as part of the litigation, advised the client and its litigation team, prepared for trial, and testified in the case which resulted in a favorable decision. These tasks took 91 days of the year. His fee produced net income of $150,000.
Martinez decided to relocate to Santiago, Chile on January 1, year 1.given the recent tragedies in Haiti and Chile, she accepted the position of assistant chief of surgery for one of the leading hospitals in Santiago specializing in the more severe medical surgeries. She found an apartment for $1,000 per month and generated net income from her professional activities of $78,000. She also won $2,000 from the national lottery in Chile. She intends to spend at least three years in Chile, immersing herself in its surgical needs. If she has not established herself by that time, she will return to the United States and resume her medical practice.
Agnew, approaching retirement, decided to give up the practice of medicine and to move to northern Canada where he could ski and snow shoe year round. Having been wildly successful in practice and amassing significant savings, he moved to Canada on January 1, year 1. Throughout the year, he derived $70,000 in dividends paid by a United States corporation, $20,000 of interest from a United States bank, $15,000 in dividends from a Canadian corporation, $5,000 in interest from a Canadian bank, and $10,000 in royalties from Canada on a book he published three years ago on medical procedures involving severe frostbite.
What tax obligations and in what amount, if any, are owed by Jackson, Martinez, and Agnew to the United States, Chile, and Canada for year 1?