On January 1 , 2 0 2 3 , Abrams, a citizen of Country Z , moved to the U S as a full time graduate student at Stanford University, studying engineering He lives in an apartment in Palo Alto Abrams is not a permanent resident of the U S ( i e , he does not have a green card ) but is present in the U S under a student visa His U S presence as a student is not counted for the substantial presence test, and he is a nonresident alien under IRC 7 7 0 1 ( b ) He does not have a residence or tax home in Country Z Abrams had not been in the U S prior to 2 0 2 3 During 2 0 2 3 , Abrams traded stocks on the Country Z stock exchange, and recognized capital gains of $ 7 5 , 0 0 0 Issue Are these gains considered U S source income

Question

On January 1 , 2 0 2 3 , Abrams, a citizen of Country Z , moved to the U   S   as a full   time graduate student at Stanford University, studying engineering  He lives in an apartment in Palo Alto  Abrams is not a permanent resident of the U   S   ( i   e   , he does not have a green card )   but is present in the U   S   under a student visa  His U   S   presence as a student is not counted for the substantial presence test, and he is a nonresident alien under IRC 7 7 0 1 ( b )   He does not have a residence or tax home in Country Z   Abrams had not been in the U   S   prior to 2 0 2 3   During 2 0 2 3 , Abrams traded stocks on the Country Z stock exchange, and recognized capital gains of $ 7 5 , 0 0 0   Issue  Are these gains considered U   S     source income

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On January 1 , 2 0 2 3 , Abrams, a citizen of Country Z , moved to the U . S . as a

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