TXX5766

Miguel is a citizen and resident of Brazil. During the current year, Miguel never visits the United States nor does he hold a green card. However, he received a dividend from Micro Corporation, received interest on a bond issued by MBI Corporation, realized a gain on the sale of ExtelCorporation stock, and realized a gain on the sale of 1,000 acres of undeveloped land located in Texas. Micro, MBI and Extel are all corporations organized in the United States. The United States does not have an income tax treaty with Brazil.

Describe the U.S. tax consequences of each of the above items of income. Also, indicate how your answers would change if Miquel held a green card.