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Please use the Bloomberg BNA research service to answer the following questions in short-answer format. Answers should include references to the appropriate treaties, Internal Revenue

Please use the Bloomberg BNA research service to answer the following questions in short-answer format. Answers should include references to the appropriate treaties, Internal Revenue Code sections, administrative regulations, and cases, if applicable as well as an appropriate analysis regarding the fact situation.


1. State University employs three international students as graduate teaching assistants. The three students each receive $1,000 per month. The student from China has been present in the United States for 6 years. The student from India has been present for 2 years. The student from Ireland has only been present in the United State for one year. How will the income received by each of the students be taxed in the US for the current year?


2. Katie is a U.S. citizen that has been living in Ireland for the past 5 years. She owns real property located in Ireland and real property located in the United States. She also owns stocks and bonds held in accounts located in both countries. Ireland imposes a tax on the net market value (less certain deductions) of the taxable assets of individuals living in Ireland. Will the tax paid on this property qualify for the foreign tax credit and/or as a deduction for U.S. tax purposes?


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