Carmen SanDiego, a U. S. citizen, is employed by General Motors Corporation, a U. S. corporation. On April 1, 2020, GM relocated Carmen to its Brazilian operations for the remainder of 2020. Carmen was paid a salary of $125,000 and was employed on a 5-day-week basis. As part of her compensation package for moving to Brazil, Carmen also received a housing allowance of $26,250. Carmen’s salary was earned ratably over the 12-month period. During 2020 Carmen worked 260 days, 195 of which were in Brazil and 65 of which were in Michigan.