A is a citizen of Colombia (South America) and is a meteorologist for a television station in the city of Bogota. After spending the first week of January 2015 on the beach in Miami, A decided to move to Miami and work as a meteorologist for a local Spanish speaking television station. A returned to Bogota and sold all her belongings over the next six months and returned to Miami on July 1, 2015 for her first day of work. She has not left the U.S. since. She was present in the U.S.180 days in 2013 and did not visit in 2014. Will she be taxed as a U.S. resident on a sale of stock sold on June 1, 2015? On July 1, 2015?

THIS ASSIGMENT IS NOT AN ESSAY. IT IS A SHORT ANSWER TYPE OF QUESTION, BUT YOU WILL NEED TO SUPPORT WELL THE ANSWER.

PLEASE NOTE THAT YOU HAVE TO BE FAMILIAR WITH THE INTERNATIONAL INCOME TAXATION CODE AND REGULATIONS. You will need to look at the reg. 301.7701(b)-1, 2, 3, and 4 REGULATIONS TO HELP YOU ANSWER THIS QUESTION. IF YOU CAN FIND ANY OTHER REGULATION OR SECTION IN THE US CODE THAT CAN HELP YOU ANSWER THE QUESTION ON WHETHER PERSON A WILL BE TAXED AS US RESIDENT ON STOCK SOLD PLEASE TAKE NOTE THAT YOU MUST CITE EVERY REGULATION OR CODE SECTION THAT YOU WILL USE. DO NOT USE ANY OTHER INFO OR ARTICLES THAT ARE NOT PRIMARY AUTHORITY.

CITATION OF THE REGULATIONS OR CODE SECTIONS ARE CRITICALLY IMPORTANT.

Thank you!