UGLOBAL.COM
where you regard your permanent home to be); citizenship (in
the case of the United States and Eritrea, regardless of where
you actually live).
In addition, one country can have different definitions of tax
residency for different purposes. For example, for income
tax purposes, the United States defines tax residency by
citizenship or residence. But, for estate and gift tax purposes,
tax residency is defined by citizenship or domicile. Yes, tax
residency can be very complex. The OECD, or Organization
for Economic Co-operation and Development, has recently
compiled a guide about tax residency for countries that have
agreed to OECD’s Common Reporting Standard.
POINT 3:
BE MINDFUL OF THE DANGER
OF BECOMING A TAX RESIDENT
OF MORE THAN ONE COUNTRY
You are a tax resident of any country where you qualify under
that country’s rules for tax residency. This means that you
could be subject to worldwide taxation by more than one
country. For example, there are many Canadian residents
with U.S. citizenship who are subject to worldwide taxation
from both Canada and the United States.
Here are two other examples of dual-tax residency. First,
U.S. citizens are always “tax residents” of the United States
regardless of where they live in the world. If a U.S. citizen meets
the conditions for tax residence in another country, he will
have dual tax residency and be subject to full taxation in both
countries. Second, a Canadian resident who spends enough
time in Portugal will become a tax resident of Portugal. He
never dissolves his Canadian tax residency and becomes a tax
resident of Portugal. He now has dual tax residency.
Dual citizenship is generally a good thing. Dual tax residency
is a bad thing. Try to avoid it. Many U.S. citizens are
renouncing U.S. citizenship because they find it too difficult
to satisfy the tax and information reporting requirements,
which result from being tax residents of more than one
country. It is also important to note that permanent residents
of the U.S. are also tax residents, regardless of where they
live. This is useful to know regarding the EB-5 program, which
grants successful applicants U.S. permanent residency
through a green card.
POINT 4:
UNDERSTAND & BE CONSCIOUS
OF WHAT IS REQUIRED TO SEVER
AN EXISTING TAX RESIDENCY
If you don’t want to be a tax resident of a country you must
sever tax residency with that country. The key point is that
you will not generally sever tax residency by simply moving
to another country. In order to sever tax residency, you
must: cease to meet the requirements that would make
you a tax resident of a country in the first place or comply
“ 对于几乎全部国家而言
一个人的
移民居住状态同他的税务居住状态
具有很大差异 ”
37