Your client is a citizen and resident of India and not a citizen or tax resident of the US. Your client has lived part time in the US during the past tax year for the first time. He still owns a home in India and spent time in both India and the US during the year. He has not determined the number of days he spent in the US during the past year. He earns a salary, dividend and interest income from US stock and bond investments, royalty income from US intangibles he licenses for use in the US, and rental income from US real property located in the US. He owns capital assets in the US that consist of both real property and personal property. The capital assets consist of stocks and bonds, a collection of vintage cars, intangibles, and real property. Your client tells you all of the capital assets he owns have appreciated in value and he wants to sell them. He wants to know how his US salary, dividend and interest income, royalty income, rental income from US real estate, and the capital gains from the sale of these assets will be taxed by the US. Advise him appropriately.

Assume he will avoid becoming a US tax resident or US citizen. If additional information is needed form the client, state what this information would be and how that would affect your conclusions.