The foreign enterprise which has no establishment or place in China but derives profit (dividend), interest, rental, royalty and other income from sources in China.

外国企业在中国境内未设立机构、场所，而有取得的来源于中国境内的利润(股息)、利息、租金、特许权使用费和其他所得。

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The royalty income from Rolex was 50% U.S.-source income not effectively connected with a U.S. trade or business.

FORBES: IRS Sand Trap For Pro Golfers

The royalty income from Upper Deck was 92% U.S.-source income not effectively connected with a U.S. trade or business.

FORBES: IRS Sand Trap For Pro Golfers

While Goosen and the IRS both agreed that personal services income, tournament bonuses and ranking bonuses should be considered US sourced, they disagreed as to what portion of the royalty income from endorsement fees should be considered US sourced.

FORBES: Tax Court to Athletes: Image Isn't Everything But It's At Least 50%