Understanding Global Tax Residency Rules
Where You Live May Not Be Where You Pay Taxes ๐งพโ๏ธ
by Stephen Morrisย CPA, MBT, CCIM
Contents
If you’re working, investing, or just living life across borders, understanding tax residency rules is key to avoiding double taxation and unexpected surprises ๐ฌ
We are a team of experienced international tax CPAs, so sit back while we break it down ๐
๐ What Is Tax Residency?
Tax residency determines which country gets to tax your income ๐๏ธ๐
๐ Itโs not always where you hold a passport
๐ Itโs not always where you โfeelโ like you live
Each country has its own rules, and they donโt always agree with each other ๐
๐ง Common Residency Tests (By Country)
| ๐ Country | ๐งช Residency Test |
| ๐บ๐ธ USA | Citizen or Green Card holder โ or 183-day rule via Substantial Presence Test |
| ๐จ๐ฆ Canada | Significant ties (home, family, bank accounts) or 183 days |
| ๐ฌ๐ง UK | Statutory Residency Test (days + ties + home base) |
| ๐ฆ๐บ Australia | Ordinary residence or domicile + intent |
| ๐ธ๐ฌ Singapore | Physical presence test (โฅ183 days) |
Most countries use days + intent + ties to determine if youโre a resident ๐๐ก๐งณ
๐จ Dual Residency? Tax Treaty to the Rescue
Sometimes two countries say you’re a tax resident ๐
Thatโs where tax treaties step in ๐งพ๐ค – they use tiebreaker rules like:
- Where your permanent home is ๐
- Where your center of vital interests lies ๐จโ๐ฉโ๐งโ๐ฆ
- Where you’re habitually resident ๐ซ
- Or even your nationality ๐
Still fuzzy? File a Form 8833 in the U.S. if youโre claiming treaty benefits ๐
๐ฆ Why Tax Residency Matters
โ
Tax rates vary – you want to avoid getting taxed twice
โ
Foreign tax credits can offset double tax (but timing + residency must align)
โ
Bank accounts, investments, real estate can all trigger reporting in the wrong country
โ
Exit taxes can apply if you renounce or leave certain countries ๐บ๐ธ๐ช
Example:
U.S. citizens are taxed on worldwide income, no matter where they live ๐๐ต
Other countries tax only residents (or source income)
๐งณ Digital Nomads & Expats: Read This
If youโre:
- ๐ด Working remotely in Bali
- ๐ Living part-time in Portugal
- ๐๏ธ Doing business from Dubai
You could trigger unintended tax residency in those places.
Some countries only require 60 days to consider you a resident (๐ Thailand, UAE, Mexico…)
๐ Make sure you have a primary residence, home country tax return, and proper visa/immigration documentation
๐งพ Tax Residency โ Immigration Status
Your tax home and your visa status donโt always match ๐คทโโ๏ธ
You can be:
- On a tourist visa but still be taxed as a resident
- A permanent resident but NOT meet the residency test
๐ Always check the income tax laws, not just immigration rules
๐งฉ Planning Tips
๐งฎ Keep track of days in each country (๐ฑ apps like TaxBird, Monaeo help)
๐ Maintain strong ties in your chosen residency (home, mail, driverโs license)
๐ File the right forms (8833, 2555, FBAR, etc.)
๐ฅ Get a cross-border advisor if you live a global life ๐
๐ฌ Final Word
If youโre international – or just living life globally – tax residency is where the puzzle starts ๐งฉ๐ผ
It affects where you file, what you pay, and even where your estate will be taxed ๐๏ธ๐ธ
Donโt leave it up to chance.
At Advise RE we see from our client profile that the world is changing. Want to review your situation across multiple jurisdictions?
๐ Let’s walk through your ties, timing, and treaties. Contact Us
Let's Talk!
Complete The Enquiry Form Below To Arrange Your Free Consultation