For people relocating from the Czech Republic to the United States

Moving to the US From The Czech Republic: Your First US Tax Year

Before your first US tax return after leaving the Czech Republic, three questions matter: when you became resident, whether the treaty makes you resident somewhere else, and what to report from the Czech Republic.

Substantial presenceGreen card testDual-status yearTie-breakerSocial security

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Quick answer

When does someone moving from the Czech Republic start paying US tax on worldwide income?

From the residency starting date: the first day in the US in a year you meet the substantial presence test, or the first day as a permanent resident under the green card test (IRS Pub 519). Before that you are a nonresident, so the first year is usually dual-status. If you are also resident in the Czech Republic, Article 4 (Resident) of the treaty decides which country you are resident in for treaty purposes.

Prepared by Illuminous Accounting · Sources checked November 11, 2026

At a glance

When you become US resident: Green card test or substantial presence test (Code section 7701(b))
First year: Usually dual-status: nonresident, then resident
Treaty tie-breaker: Article 4 (Resident)
Social security agreement: Yes, since January 1, 2009
Accounts in the Czech Republic: FBAR, Form 8938 and PFIC rules can apply once resident

Your dual-status first year

Your first US year is usually split. Before your residency starting date you are a nonresident, taxed only on US income; from that date you are a resident, taxed on worldwide income, including anything earned in the Czech Republic after the date. This is a dual-status year (IRS Pub 519).

Under the substantial presence test, the starting date is generally your first day in the US that year; up to 10 days can be ignored if you kept a closer connection and tax home abroad.
Under the green card test, it is the first day you are in the US as a permanent resident.
If you arrive late in the year and miss both tests, the first-year choice can let you be treated as resident for part of it: 31 days in a row in the US and presence on 75% of the days from then to year end, and you must meet the substantial presence test the following year.

When someone from the Czech Republic becomes a US tax resident

The US decides tax residence with two tests in Code section 7701(b), not by your visa label (IRS Pub 519). Arriving from the Czech Republic, you become a US resident for tax purposes in a year if either applies:

Green card test: you are a lawful permanent resident at any time in the year.
Substantial presence test: at least 31 days in the US this year, and 183 days over three years counting all days this year, one third of last year's and one sixth of the year before.

Count your days with our substantial presence calculator.

Dual residence with the Czech Republic

The US tests in Pub 519 do not override a treaty's own residence rules (IRS Pub 519). For people moving from the Czech Republic: Article 4 (Resident) of the treaty has the tie-breaker for someone resident in both countries: it looks first at where you have a permanent home available, then at the further tests the article lists, in the order it sets them. A US return that relies on the tie-breaker needs Form 8833 (IRS), and long-term green card holders should check the section 877A consequences first.

Reporting what you keep abroad

Do not close everything in the Czech Republic in a hurry, and do not forget it either. As a US resident you report foreign accounts on the FBAR and Form 8938 when they pass the thresholds, and many investment funds bought in the Czech Republic fall under the PFIC rules (IRS). Details: FBAR and FATCA; Form 8938.

Sources for moving from the Czech Republic

Treaty

The IRS lists the 1993 income tax treaty. General effective date (IRS Table 3): treaty Jan. 1, 1994 (IRS treaty documents for Czech Republic; treaty text; IRS Table 3).
Residence and tie-breaker: Article 4 (Resident).
Saving clause: paragraph 3 of Article 1 (General Scope).
Article 19 (Pensions, Annuities, Alimony, and Child Support), pensions.
Article 24 (Relief from Double Taxation), relief from double taxation.
Article 15 (Dependent Personal Services), employment income.

US law

US residency tests and starting dates: Code section 7701(b) (IRS Pub 519).
Treaty residence for dual residents: Treas. Reg. section 301.7701(b)-7, Form 8833 and section 6114; long-term residents: section 877A (IRS Form 8833).
Social security agreements: SSA list.

The rules of the Czech Republic on leaving the country also apply; check them with a local adviser.

How we help

We start with your travel dates and your last Czech tax year, work out the residency starting date and whether the treaty tie-breaker applies, then prepare the US return and any Form 8833. Gurleen Kaur, CPA (BC and Washington), signs. You get a written quote first.

Moving from other countries

All countries: moving to the US, by country. From Canada: moving from Canada to the US.

Common questions

Am I a US tax resident in my first year after leaving the Czech Republic?

When you meet the green card test or the substantial presence test (31 days this year and 183 weighted days over three years). Your residency starting date is generally your first day in the US that year, or your first day as a permanent resident.

What if I am resident in both the Czech Republic and the US?

Article 4 (Resident) of the treaty breaks the tie, starting with where you have a permanent home. Claiming treaty residence in the Czech Republic on a US return needs Form 8833.

Do I report my accounts in the Czech Republic after moving to the US?

Once you are a US resident, yes: the FBAR when foreign accounts total more than US$10,000, Form 8938 above higher thresholds, and PFIC rules for many foreign funds.

Is there a US social security agreement with the Czech Republic?

Yes, in force since January 1, 2009.

Sources

Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.

Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 11, 2026. This page is general information, not tax or legal advice for your situation.

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