Who is a “U.S. person?” Most guess a U.S. citizen. Some of you overachievers might have included “Green Card” holders too. But did you...

Previously, we discussed two possible remedies to the Substantial Presence test—the Closer Connections exception (general) and the Closer...

Previously I discussed the Substantial Presence Test (here) and the (General) Closer Connections Exception (here). Today, we’ll discuss a...

The Closer Connections Exception is one of the main remedies used to set aside a “substantial presence” determination, which in turn,...

Imagine strutting defiantly through U.S. airports thinking you are tax immune only to find out you might be caught in an IRS tax web....