On January 1,2023, Abrams, a citizen of Country Z, moved to the U.S. as a...
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On January Abrams, a citizen of Country Z moved to the US as a fulltime graduate student at Stanford University, studying engineering. He lives in an apartment in Palo Alto. Abrams is not a permanent resident of the USie he does not have a green card; but is present in the US under a student visa. His US presence as a student is not counted for the substantial presence test, and he is a nonresident alien under IRC b He does not have a residence or tax home in Country Z Abrams had not been in the US prior to During Abrams traded stocks on the Country Z stock exchange, and recognized capital gains of $
Issue: Are these gains considered USsource income?
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