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  1. Worth checking any relevant tax treaty. For example, the US/UK treaty apportions the compensation income from exercising non-quals to each country, based on the number of days worked there between grant and exercise divided by the total number of days between grant and exercise.

  2. 864(c)(6) should also mean that that income should be taxed as ECI income at graduated rates (and exemptions are available) as opposed to a flat 30% for FDAP.

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Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.