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British Co. has no connection with Ca whatever..except that it sends it's German nonemployee consultant to Silicon valley for 91 days to rent lab space and do innitial work on prototype. (wanted to be near the action I guess) Consultant paid 75K plus costs while working in Ca then leaves Ca forever. Can consulting and development services performed by consultant in Ca be deemed NOT Ca source income because benefit of Ca services went exclusively to British Co that owns prototype? Could fact that British Co should have registered in Ca somehow deem benefit of services back to Ca? Any help greatly appreciated