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T , a citizen of Argentina, had never visited the U . S . until February 1 , 2 0 2 4 and although T

T, a citizen of Argentina, had never visited the U.S. until February 1,2024 and although T intended to remain in the U.S. for only 2 months before T visited, T was having such a nice time that T remained in the U.S. through September 30,2024 when he returned home to Argentina. In need of money while in the U.S., on July 15,2024, T sold shares in Argento, S.A., an Argentine public company, for $400,000. T bought his shares in 2021 for $150,000 and when T arrived in the U.S. on February 1,2024, Ts shares were worth $420,000.
Ts U.S. income tax consequences will be:
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T will have a long-term capital loss of $20,000.
T will be exempt from U.S. income tax as to the sale of his Argento, S.A. shares.
Ts U.S. income tax will be 30% of his amount realized from the sale of his Argento, S.A. shares.
T will have a long-term capital gain of $250,000.

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