citizens and residents if wages are actually connected with the conduct of a trade or business in the United States. This also includes an employee working for an organization organized in the United States or an estate. “Under IRC section 864(b), with certain exceptions, the term “United States trade or business” includes the rendering of personal services in the United States” (IRS.gov, 2016) (p. 1). Any wages paid to a nonresident alien for personal services performed as an employee for an employer are generally exempt from the 30% "NRA withholding" if the wages are subject to graduated withholding (IRS.gov,