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If Carlos, a nonresident alien domiciled individual from a non - treaty country, owns shares of stock of IBM Corporation, a domestic company worth $

If Carlos, a nonresident alien domiciled individual from a non-treaty country, owns shares of stock of IBM Corporation, a domestic company worth $1,000,000, U.S. estate tax will result if Carlos dies owning those shares and U.S. gift tax will result if Carlos gifts those shares while living.

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