Wealthy Foreigners May Have Unexpected US Tax Connection

Law360 (November 1, 2019, 6:24 PM EDT) -- High-net-worth foreign individuals spending a lot of time in the U.S. may trigger taxable residency without realizing it, placing them on the hook for financial reporting obligations and potentially creating tax liability for any offshore companies they're affiliated with.

Under the Internal Revenue Code's substantial presence test, foreign individuals can establish U.S. residency — and therefore owe taxes on their worldwide income — if they spend at least 183 days in the country over three years. People who unknowingly pass this threshold can seek insulation from U.S. income taxes under their home country's treaty with the U.S., but they're still considered...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.

  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!


Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!