For people relocating from Estonia to the United States

Moving to the US From Estonia: Your First US Tax Year

Relocating from Estonia? The US decides tax residence by its own tests, your first year is usually split in two, and the US-Estonia treaty settles dual residence. Here is how each piece works.

Substantial presenceGreen card testDual-status yearTie-breakerSocial security

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Quick answer

When does someone moving from Estonia 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 Estonia, 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: None on the SSA list
Accounts in Estonia: FBAR, Form 8938 and PFIC rules can apply once resident

The two US residency tests

Test	You are a US tax resident if	Source
Green card	You hold lawful permanent resident status at any time during the calendar year	Pub 519
Substantial presence	31 days this year and 183 weighted days over 3 years (all of this year, one third of last year, one sixth of the year before)	Pub 519

These come from Code section 7701(b). A work visa, a student visa or a move for family from Estonia all go through the same two tests; some visa holders can exclude days. Try the calculator.

Resident in both countries: the US-Estonia treaty tie-breaker

During the move you can be resident in both Estonia and the US under each country's law. 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. If the treaty makes you a resident of Estonia, you can be taxed as a nonresident of the US for the treaty's purposes, but that position must be disclosed on Form 8833 under Treas. Reg. section 301.7701(b)-7 (IRS Form 8833).

Green card holders should be careful: a long-term resident who claims treaty residence abroad this way may be treated as having expatriated under section 877A (IRS).

The first US return after Estonia

The first US return after leaving Estonia is rarely a normal one.

Situation	What applies
Arrived mid-year and passed a test	Dual-status year: nonresident before the residency starting date, resident after it
Arrived late and passed neither test	Nonresident for the year, unless the first-year choice applies (31 consecutive days and 75% presence, plus the substantial presence test next year)
Married to someone still in Estonia	Special rules let some couples choose to file as residents for the whole year

Source: IRS Pub 519. See also first-year green card tax.

Accounts left in Estonia

Keeping a Estonian bank account or pension after the move is normal, but from your residency starting date the US wants to know about it. The reports are the FBAR, Form 8938 and, for many non-US funds, the PFIC rules on Form 8621 (IRS). Thresholds and deadlines: FBAR and FATCA, Form 8938.

Treaty and law references

Treaty

The IRS lists the 1998 income tax treaty. General effective date (IRS Table 3): treaty Jan. 1, 2000 (IRS treaty documents for Estonia; treaty text; IRS Table 3).
Residence and tie-breaker: Article 4 (Resident).
Saving clause: paragraph 4 of Article 1 (General Scope).
Article 18 (Pensions, Social Security, Annuities,), pensions.
Article 23 (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 Estonia on leaving the country also apply; check them with a local adviser.

How we help

Send us your arrival date, visa or green card dates and a summary of income and accounts in Estonia. We confirm your US status for the year, prepare the dual-status or resident return with the reporting it needs, and Gurleen Kaur, CPA licensed in British Columbia and Washington State, signs. Quote before any work.

Common questions

Does my visa decide my US tax residence after moving from Estonia?

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 Estonia and the US?

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

Do I report my accounts in Estonia 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 Estonia?

No, Estonia is not on the SSA list of agreement countries.

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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