5.3.1[a] U.S. Taxation of Foreign PersonsThe U.S. tax treatment of foreign persons and foreign-related transactions depends primarily on three criteria:1 – Whether the income earned...
Gross income comes from following categories of income:
Interest, Dividends, Personal Services, Rentals, Royalties, Gains from disposition of property.
Leasing generates rental income....
Ref Code Section 871 (b) and 882:
According to these code sections if a foreign person is engaged in a U.S trade or business, he is subject to U.S taxes for any income that is connected...