T came to the U.S. on a 3-year assignment which began September 1,2021 and which...

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T came to the U.S. on a 3-year assignment which began September 1,2021 and which he completes on August 30,2024, at which time T returns to his home and job abroad where he has both his closer connections and his tax home. During his 3-year assignment, T spent every day in the U.S. running the U.S. subsidiary of a foreign parent company. Later during 2024, from December 5 through December 13, T returns to the U.S. to see his daughter graduate from Penn State University where she had been attending college. On November 1,2024, T sold at a large gain his shares of stock in a foreign corporation. Assume T files the appropriate forms to claim any exceptions. Ts gain will not be subject to U.S. income tax.
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