Legal Alerts/Details

IRS Provides Relief for Stranded Travelers Impacted by COVID-19

April 24, 2020
  1. The substantial presence is met if: (1) the individual is presented in the U.S. on at least 31 days during the tested calendar year; and (2) the sum of (i) the number of days of presence in the tested calendar year; (ii) one-third of the number of days of presence in the preceding calendar year; and (iii) one-sixth of the number of days of presence in the second preceding calendar year totals 183 or more.
  2. See U.S. Tax Code Section 7701(b)(3)(D)(ii) and Treas. Reg. Section 301.7701(b)-3(c).
  3. “Eligible Individual” means any individual who (1) was not a U.S. resident at the close of the 2019 tax year, (2) who is not a lawful permanent resident at any point in 2020, (3) who is present in the U.S. (without regard to Revenue Procedure 2020-20)
  4. See Treas. Reg. Section 301.7701(b)-3(b), 301.7701(b)-2, and 301.7701(b)-7.
  5. The IRS has released a list of countries for 2019 for which eligibility requirements of Section 911(d) are waived because of war, civil unrest, or similar adverse conditions in those countries (See Revenue Procedure 2020-14, 2020-16, IR.B. 661).

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