Center of vital interests
A tax-treaty tie-breaker step: where your personal and economic ties are stronger when both countries claim you.
When you're a tax resident of two countries simultaneously, the relevant tax treaty's tie-breaker decides which country has primary taxing rights. The OECD model tie-breaker examines, in order: (1) permanent home, (2) center of vital interests, (3) habitual abode, (4) citizenship, (5) mutual agreement. 'Center of vital interests' looks at family location, principal source of income, social and cultural ties, voter registration, and where bank accounts are concentrated.
Related terms
Closer connection exception
An exception to the US Substantial Presence Test for non-citizens with stronger ties to a foreign country. Filed via Form 8840.
Casa habitación
Mexican tax-residency concept: a home maintained in Mexico that triggers residency, broader than 'principal residence'.
Contact period (Ohio)
Ohio-specific residency unit: a portion of two consecutive days during which you were in Ohio overnight.
Bona Fide Residence Test
An IRS test for the Foreign Earned Income Exclusion: bona fide residence in a foreign country for an uninterrupted tax year.
Contemporaneous records
Records made at or near the time of the events they describe. In a residency audit they are far more credible than a log rebuilt at tax time.
Abode (permanent place of)
A dwelling permanently maintained by a taxpayer, suitable for year-round use. Triggers statutory residence in many US states (NY, NJ, MA, CT, PA).
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