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Juanita, a nonresident alien, purchased a 1 0 floor fully furnished NYC office building from a domestic business that faced bankruptcy. She effectuated the purchase

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.

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