Under which of the following scenarios could Charles, a citizen of England, be eligible to claim the "closer connection" exception to the substantial presence test in 2020?
A)Charles spent 183 days in the United States in 2020 and has his tax home in England.
B)Charles spent 183 days in the United States in 2020 and has his tax home in the United States.
C)Charles spent 182 days in the United States in 2020 and has his tax home in England.
D)Charles spent 182 days in the United States in 2020 and has his tax home in the United States.

Question

Quizplus · Accepted Answer

In order for a taxpayer to qualify for the "closer connection" exception to the substantial presence test, they must meet two criteria: (1) they must have been present in the United States for fewer than 183 days during the current year, and (2) they must demonstrate that they have a "closer connection" to a foreign country than to the United States, as determined by various factors such as the location of their permanent home, family members, and personal belongings.

Option A and B both have Charles spending 183 days in the United States, making him ineligible for the "closer connection" exception. Option D has Charles having his tax home in the United States, which would suggest that he has a closer connection to the United States than to England, making him ineligible for the exception. Option C, however, has Charles spending only 182 days in the United States and having his tax home in England, which could demonstrate a closer connection to England and make him eligible for the exception.

Under Which of the Following Scenarios Could Charles, a Citizen