For people relocating from New Zealand to the United States

Moving to the US From New Zealand: Your First US Tax Year

Moving from New Zealand 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 New Zealand.

Substantial presenceGreen card testDual-status yearTie-breakerSocial security

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Quick answer

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

When someone from New Zealand 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 New Zealand, 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.

The residency starting date

Expect your first year to have two halves. Income from New Zealand before you became resident is generally outside US tax unless it is US-source; income after the residency starting date is taxed worldwide (IRS Pub 519). The starting date is your first day in the US in that year under the substantial presence test, or your first day as a permanent resident under the green card test. People who arrive near year end may be able to opt in early under the first-year choice. Getting the date right decides which New Zealand salary, bonuses and investment income the IRS sees.

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 New Zealand 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

Your accounts back home

Once you are a US resident, bank, pension and investment accounts you keep in New Zealand can bring the FBAR and Form 8938, and funds held there are often treated as PFICs (Form 8621, IRS). See FBAR and FATCA and Form 8938 for who files and the thresholds.

Treaty and law references

Treaty

The IRS lists the 1982 income tax treaty, signed July 23, 1982, amended by a 2008 protocol. General effective date (IRS Table 3): treaty Jan. 1, 1984; protocol Jan. 1, 2011 (IRS treaty documents for New Zealand; treaty text; IRS Table 3).
Residence and tie-breaker: Article 4 (Residence).
Saving clause: Article 1 (General Scope).
Article 18 (Pensions and Annuities), pensions.
Article 22 (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 New Zealand on leaving the country also apply; check them with a local adviser.

How we help

Gurleen Kaur, CPA licensed in British Columbia and Washington State, prepares the first-year dual-status return, treaty disclosures and the reporting for accounts left in New Zealand. Every engagement starts with a written quote after we review your dates and income. Also see Form 1040-NR.

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 New Zealand?

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 New Zealand and the US?

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

Do I report my accounts in New Zealand 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 New Zealand?

No, New Zealand 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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