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Topic: Tax Residence.

4 Questions 

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Topic: Tax Residence

***Note*** Please write explain your answers.

Problem 1. 

a. Maria is a resident of Brazil. Maria was present in the U.S. for 360 days in 2019, 330 days in 2020, and 60 days in 2021. Maria does not have a Green Card. Is Maria a U.S. resident for U.S. tax purposes in 2021?

b. Same facts as in a. above, except that but Maria was a student and was studying in the U.S. on a student F-1 visa in 2019. Is Maria a U.S. resident for U.S. tax purposes in 2021?

Problem 2. 

a. Ngasa Corp. is a corporation organized under the laws of Japan. Ngasa Corp. has an office in New York where the Executive Board meets to make management decisions for the company. Is Ngasa Corp. a U.S. resident for U.S. tax purposes?

b. Big Time Inc. is a corporation organized under the laws of Delaware. For its quarterly Executive Board meetings, the Big Time Inc. Executive Board flies by private jet to the Bahamas for a long weekend at a prestigious Luxury Resort and conducts its meetings to make management decisions for the company. Putting aside the ethics of the Executive Board’s actions, is Big Time Inc. a U.S. resident for U.S. tax purposes?

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