On July 1, 2022, A obtains an immigration permanent resident alien green card thus becoming a U.S. income tax resident alien. A was a U.S. income tax nonresident alien prior to that time. In 2010, while A was a U.S. income tax nonresident alien, A acquired shares of stock in a foreign corporation at a cost of $200,000 and on October 1, 2022, A sells such foreign corporation shares for $2,200,000. On July 1, 2022, the date on which A became a U.S. income tax resident alien, the shares had a fair market value of $2,400,000. With respect to A's October 1, 2022 sale, A will be subject to U.S. income tax as follows:

A will recognize a $2,000,000 gain.

A will recognize neither gain nor loss.

A will recognize a $200,000 loss.

A will recognize a $200,000 loss.