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Mr A is a citizen of Country X (other than Canada or Mexico) which entered into an income tax treaty with the US containing identical
Mr A is a citizen of Country X (other than Canada or Mexico) which entered into an income tax treaty with the US containing identical provisions to those in the 2016 Model Treaty reprinted in your M&S text. Country X domestic law taxes the worldwide income of its citizens just as the US taxes its citizens under a provision similar to 7701(a)(30). Likewise, from the US perspective, Mr A is a RA because his US presence in the current year is sufficient to trigger US residency under the 7701(b) substantial presence test for the entire year. He has a permanent home available to him in both countries. Under a subjective analysis, his center of vital interests is in Country X. Will the United States tax his worldwide income in the current year? Group of answer choices No, because the regular commuter rule of 7701(b)(7)(b) governs this situation. Yes, because 7701(b) overrides Article 4 of the 2016 Model Treaty. Yes, but only to the extent of 50% of Mr A's worldwide income under Article 4(1) of the treaty. No, because Article 4(3)(a) of the Treaty governs this situation None of the foregoing provides the correct
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