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N is a citizen of Argentina who is a successful actor. He entered the United States on 1 March 2 0 2 1 . (
is a citizen of Argentina who is a successful actor. He entered the United States on
March He had never been to the United States before that except for a vacation from
February in Maine. Between March and May N stayed with his
daughter and her family at her home in Jacksonville except for a vacation trip from
December through December when he was in Argentina for Christmas. He was not
in the United States any part of those days. While at his daughter's home, received
royalties of $ per month from webcasts he recorded in Argentina, reading books on
US tax law in Spanish for the target audience. The webcasts are only available in Argentina.
He also earned $ per month performing on stage at a Jacksonville theater as the lead
in the smash musical comedy, "The Tax Man Cometh".
The only other income received while he was in the United States was income from the
rental of his home in Argentina for the period from March through December
did not want to sell his home in Argentina since he knew he would return to
Argentina. In fact, N terminated his lease with the Argentine tenant in December in
anticipation of returning to Argentina sometime in The gross rent received in US $
equivalent was $ per month, payable on the first day of each month. If allowed as a
deduction from rental income, incurred monthly interest expense of $ and
depreciation of $ He would have no deductions to claim against his royalty income.
N departed the United States and returned to live in Argentina on May Later in
October of that same year, he sold stock in UNF Inc., a corporation organized under Florida
law. UNF Inc. is not a US Real Property Holding Corporation. We have not studied the
importance of US Real Property Holding Corporation but I didn't want to confuse you in
case you have read M&S Chapters beyond Chapter and started to overthink this question.
His gain was $ million. He sold the stock to a US partnership. In October N made a
trip to Jacksonville to close the deal there, arriving on October and leaving on
October He visited friends in the United States from through May
The cumulative number of days resulting from application of the substantial presence test to
determine Ns residency status for is Please fill in the blank. Just insert a whole
number, eg
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