When Does a Foreign Citizen Become a U.S.
Resident
for Income Tax Purposes?
Consider the following situation:
Facts: A non-U.S. person (non-citizen, non-resident
and non-green card holder) is considering purchasing a home in
Santa Barbara.
Issue: How many days per year may he stay in the U.S.
without becoming a resident for U.S. income tax purposes?
NOTE: The balance of this article has been incorporated into the Tax Prophet's Action Guide entitled, "Foreign Investors: U.S. Income, Gift and Estate-Tax Consequences" described below:
Non-U.S. taxpayers investing in the United States encounter a series of complex income, gift and estate-tax rules. In addition, stay in the U.S. too long and you could become subject to U.S. income taxes on your world-wide income! This Action Guide discusses the common tax traps facing non-U.S. taxpayers and how to avoid them. It is a must read for these taxpayers and their advisors.
