Relief on Substantial Presence and Treaty Day-Count Tests.
On May 30th, the IRS issued Revenue Procedure 2020-20 which provides non-U.S. individuals present in the U.S. some limited relief from the day-count tests for U.S. tax residency and for eligibility for certain treaty benefits. The relief comes in the form of the “COVID-19 Medical Condition Travel Exception”. The name of the exception is a misnomer because individuals need not have had any medical condition (including the COVID-19 virus) to claim its benefits. Continue Reading