tax. Even if the Panamanian company relocated its headquarters from Miami, it would likely still be considered to be engaged in a U.S. trade or business as there is a continuous and systematic presence in the United States. For example, with 90% of customers being US citizens or residents and docking at US ports daily, these cruise ships would be perceived as still having a true principal place of business. Treating this income as coming from the United States and effectively connected to a U.S. trade or business would make the income subject to U.S. taxes at the same rate as other income, for example the corporate income tax rate is 35%. Along with this tax, Senator Rockefeller's bill called for imposing a 5% excise tax, which would be used to finance the infrastructure that ships benefit from. The Rockefeller bill would impose this excise tax on the gross income of cruises “that embark or disembark passengers in the United States.” Generally, cruises with a majority of passengers embarking or disembarking in the United States would be subject to all gross income from that voyage. to excise duty. However, for cruises that call at a U.S. port, but do not actually embark or disembark the majority of passengers in the United States, only half of the gross income from that voyage would be subject to tax. According to Senator Rockefeller, the excise tax is similar to passenger taxes in aviation and the gas tax for motors