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Guide: Moving to USA

Matthew Marcarian   |   21 Jun 2017   |   1 min read

Overview of U.S. Tax Residence Rules

The taxation of aliens by the United States is significantly affected by the residency status of such aliens.

Although the immigration laws of the United States refer to aliens as immigrants, non-immigrants, and undocumented (illegal) aliens, the tax laws of the United States refer only to ‘resident’ and ‘nonresident aliens’.

In general, the controlling principle is that ‘resident aliens’ are taxed in the same manner as U.S. citizens on their worldwide income, and ‘nonresident aliens’ are taxed according to special rules contained in certain parts of the Internal Revenue Code.

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Determining Corporate Residency

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Corporate Residency

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Determining Corporate Residency

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Place of
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Determining Corporate Residency

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Central Management
and Control

Is the Central Management and Control
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Determining Corporate Residency

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Carry on a Business

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Determining Corporate Residency

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Voting Power

Is the company's voting power controlled
by shareholders who are residents of Australia?

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The company is an Australian Resident

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regarding your client's specific situation.

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Determining Corporate Residency

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The company is not a resident
but it could be a CFC

Contact us for tailored international tax advice
regarding your client's specific situation.

Contact us for tailored international tax advice regarding your client's specific situation.

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Determining Corporate Residency

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