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On January 1,2023, Abrams, a citizen of Country Z, moved to the U.S. as a...

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Accounting

On January 1,2023, Abrams, a citizen of Country Z, moved to the U.S. as a full-time graduate student at Stanford University, studying engineering. He lives in an apartment in Palo Alto. Abrams is not a permanent resident of the U.S.(i.e., he does not have a green card); but is present in the U.S. under a student visa. His U.S. presence as a student is not counted for the substantial presence test, and he is a nonresident alien under IRC 7701(b). He does not have a residence or tax home in Country Z. Abrams had not been in the U.S. prior to 2023. During 2023, Abrams traded stocks on the Country Z stock exchange, and recognized capital gains of $75,000.
Issue: Are these gains considered U.S.-source income?

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