For people relocating from Finland to the United States

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

Relocating from Finland? The US decides tax residence by its own tests, your first year is usually split in two, and the US-Finland 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 Finland 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 Finland, Article 4 (Residence) 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 (Residence)
Social security agreement: Yes, since November 1, 1992
Accounts in Finland: 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 Finland 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.

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 Finland all go through the same two tests; some visa holders can exclude days. Try the calculator.

The treaty tie-breaker

Article 4 (Residence) 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.

Point	What it means
Who uses it	People resident in both Finland and the US under each country's own rules, typically in the year of the move
How it is claimed	Form 8833 with the US return, under Treas. Reg. section 301.7701(b)-7 (IRS)
Risk for green card holders	Long-term residents may be treated as expatriated under section 877A

Reporting what you keep abroad

Do not close everything in Finland 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 Finland fall under the PFIC rules (IRS). Details: FBAR and FATCA; Form 8938.

Sources for moving from Finland

Treaty

The IRS lists the 1989 income tax treaty. General effective date (IRS Table 3): treaty Jan. 1, 1991; protocol Jan. 1, 2008 (IRS treaty documents for Finland; treaty text; IRS Table 3).
Residence and tie-breaker: Article 4 (Residence).
Saving clause: paragraph 3 of Article 1 (Personal Scope).
Article 18 (Pensions, Annuities, Alimony, and Child Support), pensions.
Article 23 (Elimination of 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 Finland on leaving the country also apply; check them with a local adviser.

How we help

We start with your travel dates and your last Finnish 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.

Common questions

When do I become a US tax resident after moving from Finland?

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 Finland and the US?

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

Do I report my accounts in Finland 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 Finland?

Yes, in force since November 1, 1992.

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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