For people relocating from Japan to the United States

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

Moving from Japan to the US changes your tax position in stages. This guide covers when US residency starts, the dual-status first year, the treaty tie-breaker and what happens to accounts you keep in Japan.

Substantial presenceGreen card testDual-status yearTie-breakerSocial security

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Quick answer

When does someone moving from Japan 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 Japan, 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 October 1, 2005
Accounts in Japan: FBAR, Form 8938 and PFIC rules can apply once resident

When someone from Japan 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 Japan, 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.

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 Japan 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.

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

During the move you can be resident in both Japan and the US under each country's law. 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. If the treaty makes you a resident of Japan, 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).

Reporting what you keep abroad

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

Where these rules come from

Treaty

The IRS lists the 2003 income tax treaty, signed November 6, 2003, amended by protocols listed for 2003 and 2013. General effective date (IRS Table 3): treaty Jan. 1, 2005; protocol Jan. 1, 2020 (IRS treaty documents for Japan; treaty text; IRS Table 3).
Residence and tie-breaker: Article 4 (Residence).
Saving clause: subparagraph (a) of paragraph 4 of Article 1 (General Scope).
Article 17 (Pensions, Social Security, Annuities, and Support Payments), pensions.
Article 23 (Relief from Double Taxation), relief from double taxation.

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 Japan 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 Japan. 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

Am I a US tax resident in my first year after leaving Japan?

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 Japan and the US?

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

Do I report my accounts in Japan 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 Japan?

Yes, in force since October 1, 2005.

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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