{"id":741,"date":"2012-11-27T19:45:26","date_gmt":"2012-11-27T14:15:26","guid":{"rendered":"http:\/\/www.nsglobal.com\/blog\/?p=741"},"modified":"2013-03-13T16:34:01","modified_gmt":"2013-03-13T11:04:01","slug":"irs-issues-memo-on-%e2%80%9ctie-breaker%e2%80%9d-rule-under-a-tax-treaty","status":"publish","type":"post","link":"https:\/\/www.nsglobal.com\/blog\/?p=741","title":{"rendered":"IRS issues memo on \u201cTie breaker\u201d rule under a tax treaty"},"content":{"rendered":"

A recent IRS memo addresses the U.S. tax status of a U.S. citizen deemed to be a resident of a foreign country under a tax treaty “tie breaker” rule.<\/p>\n

The memo was issued with respect to Israel, but the general rule stated at the conclusion of the memo would seem to apply to other treaty countries with such a tie breaker rule as well.<\/p>\n

This is what was stated at conclusion:<\/p>\n

\u201cA U.S. citizen who is treated as a resident of another country under an income tax treaty would still be required to file a Form 1040 (assuming his income meets the filing thresholds) and would still be subject to U.S. tax on his worldwide income (except to the extent one of the exceptions to the saving clause applies).\u201d<\/p>\n

You can read the entire memo here . . . . http:\/\/1.usa.gov\/Wtl65m<\/a><\/p>\n

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