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Residency Rules/Ramifications


U.S. citizens and U.S. residents are generally taxable in the U.S. on their worldwide income/deductions. Nonresidents of the U.S. are generally taxable on their U.S. source income/deductions. U.S. internal income tax law generally defines a resident as a green card holder or any other non-U.S. citizen who meets a substantial presence test of days of physical presence in the U.S. over a three year period. Income tax treaties with other countries may be utilized, if applicable, to change an individual’s residency status. There are also elections that, if applicable, can be made to change from one residency status to another for U.S. income tax purposes.​ We can assist with evaluating residency rules and the resulting consequences. For more information please see Rödl Tax Matters.


Elisa Fay


Partner-in-Charge Rödl National Tax

+1 404 525 2600

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