His servers are in the UK and his company is in the UK. Since the 'service' is performed in the same country that the business is located, the income does NOT q

His servers are in the UK and his company is in the UK. Since the 'service' is performed in the same country that the business is located, the income does NOT qualify as 'Foreign base company services income'. (see 26 USC § 954 E 1 B) Any money repatriated to the U.S. (e.g. if he pays himself) is taxable income.