Matthews is a citizen and resident of Country X$.$ In $2021,$ he sells stock in DomesticCo, a publicly traded U$.$S$.$ company and recognizes a large gain. In addressing the issues below, please take into account the following: In the case of the sale of stock $($which for tax purposes is $$personal property$),$ the sale is U$.$S$.$ source only if it meets the requirements of Sections $865($a$)$ and $($g$).$ Section $865($a$)$ says that income from the sale of personal property is U$.$S$.$ source only if the seller is a U$.$S$.$ resident, and Section $865($g$)$ provides a special definition of $$resident$$ that applies only to Section $865.$

Issue $1$: What are the U$.$S$.$ tax consequences of this gain to Matthews if he is never present in the U$.$S$.?$ Separately provide the relevant rules, analysis, and conclusion under the following headings:

Rule:

Analysis:

Conclusion: