Question
A is a Brazilian lawyer (and citizen/resident), who visited the U.S. for the first time in 2019, staying 50 days, primarily for business reasons, in
A is a Brazilian lawyer (and citizen/resident), who visited the U.S. for the first time in 2019, staying 50 days, primarily for business reasons, in New York City. In 2019, A earned the following items of income:
A. $100,000 salary paid (by his law firm) in Brazil to his Citibank account.
B. $1,000 honorarium paid by a group of Latin American law students, for whom he was invited to lecture while in New York.
C. $5,000 dividends paid on IBM stock he bought 5 years ago, through an online broker.
D. $1,000 paid on a CD (certificate of Deposit) paid by Citibank (a U.S. corporation) to his account in Brazil (in the Brazilian branch of Citibank).
E. $1,000 gain on the sale of a zero-coupon bond of a U.S. corporation that he bought in 2004 and sold on Dec. 31, 2005, while in Brazil, to a Brazil citizen and resident.
F. $10,000 gain on a painting of the Grand Canyon that he found in the attic of his house, and sold to a U.S. business partner of his. He shipped the painting to the city at his expense, including the insurance, by FedEx.
G. $1,000,000 guaranteed payment on his money market account held in a Swiss bank and paid by the New York Branch of that bank while he was in New York.
H. B, his Brazilian friend’s paid him $20,000 with respect to a loan of $10,000 that A made to B last year and never thought about it since.
I. $10,000 profit on hand-made dolls that A produces at home and normally ship to the U.S. at the expense of his U.S. (one) customer, but this year brought into the U.S. by A in a suitcase and delivered by hand to the customer in New York. This is a hobby and A is under no obligation to produce these dolls - the customer will purchase whatever produced whenever produced at the agreed price and quality specifications. Alternatively, A purchases the dolls from a neighbor who regularly sells the dolls in his shop in Brazil.
J. $1,000 for the exclusive worldwide distribution rights of a book he wrote in English for American lawyers with Brazilian customers.
How much U.S. source income does A have in 2005?Step by Step Solution
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