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International Taxation: Status of Don, a citizen of Great Britain, in the US

1. Don is a citizen of Great Britain and a famous race car driver. He decides to come to the U.S. to open a car dealership in Detroit. Don does not obtain a green card or U.S. citizenship, but he procures a visa to work in the U.S. He is in the U.S. during the following periods:
? 2008: April 1 through August 1
? 2009: June 1 through August 1

Which of the following best describes Don's status?
(a) Resident alien under the green card test.
(b) Nonresident alien.
(c) Resident alien under the substantial presence test.
(d) Citizen of the U.S.

2. Don is a citizen of Great Britain and a famous race car driver. He decides to come to the U.S. to open a car dealership in Detroit. He is in the U.S. during the following periods:
? 2008: April 1 through August 1
? 2009: March 1 through August 1

Which of the following best describes Don's status?
(a) Resident alien under the green card test.
(b) Nonresident alien.
(c) Resident alien under the substantial presence test.
(d) Citizen of the U.S.

3. Don is a citizen of Great Britain and a famous race car driver. He decides to come
to the U.S. to open a car dealership in Detroit. Don doesn't obtain citizenship, but
he procures a green card on June 30, 2009. He is in the U.S. during the following
periods:
? 2008: April 1 through August 1
? 2009: June 1 through August 1

Which of the following best describes Don's status?
(a) Resident alien under the green card test.
(b) Nonresident alien.
(c) Nonresident alien under the green card test.
(d) Citizen of the U.S.

4. USAco expands its operations to foreign country F. During the current taxable year, USAco's country F operations have a net profi t of $100,000. USAco retains the earnings in foreign country F. On its Form 1120 for the current taxable year, USAco will report net profi t from its foreign operations of:

(a) $100,000 if the foreign operations are conducted as a branch and $0 if the foreign operations are conducted as a subsidiary.
(b) $0 if the foreign operations are conducted as a branch and $100,000 if the operations are conducted as a subsidiary.
(c) $0, regardless of whether the foreign operations are conducted as a subsidiary or a branch.
(d) $100,000, regardless of whether the foreign operations are conducted as a subsidiary or a branch.

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ANSWERS

Question 1
ANSWER: C
The test is you've been in the US for at least 31 days during the calendar year and have been in the US for 183 days within the last three years

Question 2
ANSWER: C
The test is you've been in the US for at least 31 days ...

Solution Summary

International taxation is examined. The status of Don a citizen of Great Britain in the United States is determined.

$2.19