Professional Custom Accounting Papers: Is the gain subject to U.S. tax under the following circumstances?
Question
Jose, a citizen of Mexico, realized gain on selling stock of a Delaware corporation that does business only in the United States. Is the gain subject to U.S. tax under the following circumstances?
a) Jose has never been physically present in the United States?
b) Jose is present in the United States for a continuous period of 185 days during the taxable year, but is not present in the United States at any other time?
