I. The Residence of Individuals

Individual residents of the United States, regardless of nationality, must pay U.S. tax on their worldwide income. U.S. taxation of nonresident aliens, by contrast, is largely limited to income from sources in the United States. Therefore, residence is the first and most important touchstone of U.S. taxation for foreign nationals.

Residence is a measure of the extent and permanence of an individual’s presence in a given place. The notion of residence, which has bearing in many legal contexts, took on a life of its own early on in the realm of taxation. Even within taxation, the notion of residence is now made up of several separate strands. Read More