Question
Please analyze the following fact-pattern as to whether the taxpayer should meet the requirements of a qualified individual under the bona fide resident test set
Please analyze the following fact-pattern as to whether the taxpayer should meet the requirements of a qualified individual under the bona fide resident test set forth in IRC sec. 911(d)(1)(A). The taxpayer is an American citizen who was born and raised in Alaska and is an airline pilot employed by Japan Airlines. He flies routes within Japan. He lives in a hotel room while in Japan. He cannot speak Japanese and is culturally unassimilated. His wife continues to live in Alaska. He declined a dividend check from the state of Alaska awarded to Alaska residents. He paid Japanese tax on his earnings. Is he a qualified individual? What are the tax advantages of satisfying the qualified individual test? What does tax home mean as that term is used in IRC Sec. 911(d)(1)?
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