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Closer Connection Exception to the Substantial Presence Test | Internal Revenue Service

irs.gov · 1,001 words · saved by 1 readers

You will be considered to have a closer connection to a foreign country than the United States if you or the IRS establishes that you have maintained more significant contacts with the foreign country than with the United States.

Even if you met the substantial presence test, you can still be treated as a nonresident of the United States for U.S. tax purposes, within Internal Revenue Code Section 7701(b)(1)(B), if you: Were present in the United States less than 183 days during the year, and Had a closer connection during the year to one foreign country in which you had a tax home than to the United States (unless you had a closer connection to two foreign countries, discussed next), and Maintained a tax home in that foreign country during the entire year (see Chapter 28 of Publication 17 for a discussion of the tax ho

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