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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 . (

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N is a citizen of Argentina who is a successful actor. He entered the United States on 1
March 2021.(He had never been to the United States before that except for a vacation from
1-5 February 2021 in Maine.) Between 1 March 2021 and 31 May 2023, N stayed with his
daughter and her family at her home in Jacksonville except for a vacation trip from 18
December through 31 December 2022 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, N received
royalties of $35,000 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 $10,000 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 N received while he was in the United States was income from the
rental of his home in Argentina for the period from 1 March 2021 through 31 December
N 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 2022 in
anticipation of returning to Argentina sometime in 2023. The gross rent received (in U.S. $
equivalent) was $12,000 per month, payable on the first day of each month. If allowed as a
deduction from rental income, N incurred monthly interest expense of $3,000 and
depreciation of $2,000. He would have no deductions to claim against his royalty income.
N departed the United States and returned to live in Argentina on 31 May 2023. Later in
October of that same year, he sold stock in UNF Inc., a corporation organized under Florida
law. (UNF Inc. is not a U.S. Real Property Holding Corporation. We have not studied the
importance of U.S. Real Property Holding Corporation but I didn't want to confuse you in
case you have read M&S Chapters beyond Chapter 3 and started to overthink this question.)
His gain was $2 million. He sold the stock to a U.S. partnership. In October 2023, N made a
trip to Jacksonville to close the deal there, arriving on 10 October 2023 and leaving on 12
October 2023. He visited friends in the United States from 2 through 9 May 2024.
The cumulative number of days resulting from application of the substantial presence test to
determine N's residency status for 2021 is Please fill in the blank. (Just insert a whole
number, e.g.,365).
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