Juanita, a nonresident alien, purchased a $10$ floor fully furnished NYC office building from a domestic business that faced bankruptcy. She effectuated the purchase through her wholly owned U$.$S$.$ corporation, which until that point in time had engaged in the sole activity of owning the rights to a patent she intends to license in the future. She believes that the time has not yet come to exploit the patent despite her estimate of $$10,000,000$ value for that patent. She has never visited the U$.$S$.$ and has performed all the activities related to this business through unrelated persons that were paid in cash and at arms$-$length from her Mexican bank account. Her business model is to rent office space to anyone for whatever period is required. She can divide the space almost at will with a set of moving walls already installed in the building when she bought it$.$ In $2022,$ after $3$ years of hefty profits from the building, she found in one of her rental clients a company that she believes would be a good match for the patent. Indeed, Smith Enterprises $($Smith$),$ a domestic corporation immediately offers her $$5,000,000$ for the patent and an additional $$5,000,000$ for the whole office building that Smith expects to need upon the acquisition of the patent. She ends up selling the stock of her U$.$S$.$ corporation to Smith realizing a $$10,000,000$ gain. Does she have any effectively connected income for the year of the stock sale? Please explain.