There are many reasons to own real estate and some form of residence in the United States: Access to superior education in one of the Ivy League Universities, vibrant culture in New York or world class health services in the Mayo clinic. Generally US taxation is less competitive than most other destinations we offer our relocation services for. In order to avoid US worldwide income taxation there are alternatives for Green Cards available such as L-1 intracompany manager executive transfers or E1/2 treatey/investor visas (which can normally be renewed indefinetely. It is very important to observe the clear rules as to when a foreigner becomes resident for tax purposes in the U.S. Assuming adequate immigration status, up to an average of 120 days can be spent in the United States without residency status there being established for U.S. income-tax purposes. Under the substantial presence test, a foreign citizen is treated as a U.S. resident alien if that individual is present in the United States for at least thirty-one days during the current calendar year and for a total of 183 days during the current year and the two preceding calendar years. In determining whether this 183-day requirement has been satisfied, the days are counted differently, depending on when the physical presence in the United States occurred. Each day of presence during the current year is counted as a full day. Each day in the first preceding year counts as one third of a day. Each day during the second preceding year counts as one sixth of a day.

There is an important exception to this general rule, in addition to the possible applicability of a tax treaty. If a foreigner is present in the United States for fewer than 183 days in a calendar year, and has a tax home in another country and a closer connection to that country than to the United States for that calendar year, the foreigner is not considered a resident of the United States for income tax purposes for that calendar year. This exception, known as the "Tax Home/Closer Connection Exception," defines "tax home" as the individual's principal place of business. The Tax Home/Closer Connection Exception is not available to a foreigner who has taken steps to become a lawful permanent resident of the United States. This Exception allows foreigners to reside in the US in a given year for longer than the days allowed under the "cumulative presence" test, so long as they are present in the country for less than 183 days in that year.