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- Title
Global View: Nonresident Aliens Pursuant to Treaty Tie-Breakers Do Not Have to File FBARs.
- Authors
Misey Jr., Robert J.
- Abstract
The article explores the determination of U.S. residency for tax purposes, particularly through treaty tie-breaker rules. Topics include tests for U.S. residency, treaty tie-breakers determining non-resident alien status, and the Foreign Bank Account Report (FBAR) filing requirements for U.S. persons. It outlines various tests for U.S. residency, such as the green card test and substantial presence test, highlighting how these tests impact taxation on worldwide income.
- Subjects
NONRESIDENTS; DOUBLE tax agreements; TREATIES; INCOME tax
- Publication
Journal of Tax Practice & Procedure, 2024, Vol 26, Issue 1, p24
- ISSN
1529-9279
- Publication type
Article