id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-338	Hoose, Mark S.	Trading One Danger for Another: Creating U.S. Tax Residency while Fleeing Violence at Home	2022	40	.pdf	application/pdf	16780	983	62	This means that income of a U.S. citizen is taxed by the United States regardless of where the income is earned and where the individual resides.3 In addition to U.S. citizens (whether born or naturalized), this system also applies to lawful permanent residents (“green card” holders) of the United States, who are considered to be U.S. residents for U.S. federal income tax purposes.4 What is less well-known is that individuals who are neither citizens nor lawful permanent residents of the United States can also be considered to be U.S. residents for purposes of the U.S. federal income tax, and hence subject to U.S. tax on their worldwide income.5 These individuals can create U.S. tax residency by satisfying the “substantial presence test,” which essentially provides that an individual who is “present” in the United States for a certain number of days over a given period can create U.S. tax residency by means of this “substantial presence. U.S. TAX RESIDENCY UNDER U.S. TAX TREATIES If an individual is deemed to be a U.S. tax resident under the Internal Revenue Code, the analysis does not necessarily end at this point.152 If the individual is entitled to the benefits of a tax treaty between her home country and the United States, then the person may be able to avoid U.S. tax residency status.153 147.	cache/ftr-338.pdf	txt/ftr-338.txt