Note:Unless otherwise indicated, assume that the U.S. Model Income Tax Convention of

November 15, 2006 (the "Model Treaty").

Bill, a citizen of country F, lives in the United States. Bill is 45 years old and has not lived in country F since he left F at the age of 18. Although his parents and most of his relatives still live in F, Bill lives in the U.S. where he has owned a home for 10 years. Under the Model Treaty, Bill is a resident of:

the United States..

country F.

both the U.S. and country F.

neither the U.S nor country F.