Pedro, a Nonresident Alien, Licenses a Patent to a U

Multiple Choice

Pedro, a nonresident alien, licenses a patent to a U.S. company for an $11 per unit fee for each unit produced. As a result of receiving the fee, Pedro must recognize the fee as

A) ordinary income taxable in the United States.
B) capital gain taxable in the United States.
C) no gain or income taxed in the United States.
D) a portion of the gain, depending on the number of days Pedro is physically present in the United States during the current year.