Treaties between the United States and other countries provide for special rules that will potentially override the standard tax treatment found in the Internal Revenue Code.  The taxpayer in the case of Cole v. Commissioner, TC Summary Opinion 2016-22 believed he had found a provision that would remove from tax the gain on sale of stock he had disposed of following becoming a permanent resident of Israel.

Mr. Cole in the year in question was both a United States citizen and a permanent resident of Israel.  He had purchased shares of Neogen Corporation prior to moving to Israel.  After moving to Israel he sold those shares for a net gain of $114,947.