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Determine the US tax classification of the following entities. Singapore Public Limited Company German GmbH where all shareholders have limited liability Canadian ULC that is

  1. Determine the US tax classification of the following entities.
    1. Singapore Public Limited Company
    2. German GmbH where all shareholders have limited liability
    3. Canadian ULC that is owned by two shareholders
  2. Sarah has never been in the United States prior to arriving in California on January 11, 2021. Sarah moved to California after having applied for (and received) a green card. She has lived in California since that time.
    1. Is Sarah a resident alien in 2021?
    2. If yes, under what test?
    3. What is her residency starting date?
  3. Same facts as 2 except Sarah moved on January 11, 2021 to California but only received her green card on November 15, 2021.
    1. Would your answer change and why?
  4. Helen, a citizen of Russia, was present in the US for 90 days in 2021, 120 days in 2020 and 150 days in 2019. Helen does not have her green card.
    1. What is Helens US residency status in each of the three years?

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