Ricardo, a citizen of Peru, sold his Peruvian business, FC, a Peruvian company back in 2015 while then a resident of Peru. Ricardo sold FC for $10,000,000 to be paid $1,000,000 a year for 10 years. Ricardo's basis in FC was $2,000,000, gain is $8,000,000 and his gross profit percentage is 80%. Ricardo had never been in the US before 2022 and in 2022 Ricardo spends 250 days in the US thus becoming an RA. Disregarding any interest factor, Ricardo will have to recognize $800,000 of gain for U.S. income tax purposes in 2022.

True

False