Casey is a U$.$S$.$ citizen employed by a multinational corporation at its London office. Casey is married to Michael, a British citizen, and they reside in England. Michael receives substantial rent income from real estate he owns in western Europe.

Question Content Area

a$.$Must Casey file a U$.$S$.$ income tax return?

Yes, because she is a U$.$S$.$ citizen.No$,$ because she is not a resident of the United States.

Question Content Area

b$.$Under what circumstances might Michael be considered a resident of the United States?

If Casey and Michael

have been married for least five yearsmake an election under $6013($g$)$claim dual residency

Michael may be considered a resident of the United States.

Assuming that Casey and Michael do file a joint return, what are the tax consequences?

If they file a joint return, Michael's non$-$U$.$S$.$ source income would not be subject to the U$.$S$.$ tax.If they file a joint return, Michael's non$-$U$.$S$.$ source income will be subject to U$.$S$.$ tax.