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ACA and ITIN holders


Hugo

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This would be code "C" which comes under the following directive. Also, you might want to take some time and review the instructions for form 8965 that specifically state what the exemptions are and what category you clients may fall under.

Citizens living abroad and certain noncitizens - You are: •A U.S. citizen or resident who spent at least 330 full days outside of the U.S. during a 12-month period;

•A U.S. citizen who was a bona fide resident of a foreign country or U.S. territory;

•A resident alien who was a citizen of a foreign country with which the U.S. has an income tax treaty with a nondiscrimination clause, and you were a bona fide resident of a foreign country for the tax year; or

•Not a U.S. citizen, not a U.S. national, and not an alien lawfully present in the U.S.

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