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Carlos is an individual citizen and resident of Brazil. His start-up company negotiates cooperation with a U.S. corporation, which requires him to visit the U.S.

  1. Carlos is an individual citizen and resident of Brazil. His start-up company negotiates cooperation with a U.S. corporation, which requires him to visit the U.S. Does Carlos satisfy the objective substantial presence test of IRC section 7701(b)(3)(A) in the following cases?
    1. He spent the 1st 3 full months of Year 1 thru Year 3 In the U.S. Does Carlos meet the substantial presence test in Year 3?
    2. He spent 360 days in the U.S. in each of Year 1 and Year 2 and the whole month of June in Year 3. Does Carlos meet the substantial presence test in Year 3?

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