TRUE OR FALSE:

1. N, a nonresident alien individual, was born in Country X and has resided there for the past 40 years. N is the president of a large department store in Country X and is also actively involved in civic, business, social and charitable activities in Country X. Concerned about a recent military coup in Country X, N accepts his opportunity to obtain a green card and he visits the U.S. on May 10,2015 to get his card. Unfortunately, N is killed in an automobile accident in the U.S. on May 15,2015 before his scheduled October 1, 2015 return to Country X. N is a resident decedent for U.S. estate tax purposes.

2. A (a U.S. citizen), B (an NRA), FlaCo (a Florida Corporation), and FCo (a foreign corporation) each own 1/4 interest in a Florida general partnership which is involved in real estate development. In years 2011 through 2014, the partnership generates a $100,000 operating loss and each partner files its appropriate U.S. income tax returns to record its respective losses. In 2015, the partnership generates effectively connected taxable income ("ECTI") of $400,000 and each partner has $100,000 of ECTI allocated to it. Even though both B (an NRA) and FCo (a foreign corporation) have sufficient losses to offset the 2015 ECTI, under the general rule, the partnership must withhold U.S. income tax with respect to their 2015 ECTI.