The client (nonresident alien) is planning to sell the software to his C-Corp. The software is custom made, not off-the-shelf one, so it will be entirely depreciated within 3 years. Under the IP assignment agreement, the C-Corp must pay for the software in 1 payment within 5 years - after full depreciation. The C-Corp uses cash accounting method. So, do I get it right: (1) that the C-Corp may depreciate the software before it pays for it; (2) the IP seller (NRA) will not have to pay any taxes except personal income tax on the amount of the entire software price; (3) NRA's income will be ECI, not FDAP?