We made a change to the Form 8833 (Treaty-Based Return Position) flowchart that we published earlier this week. The change relates to residency of individuals that are dual resident taxpayers. Treas. Reg. §301.6114-1(c)(2) provides that Form 8833 is required for individuals claiming that residency is determined under a treaty only if the income items reportable from the change in residency are greater than or equal to $100,000. However, Treas. Reg. §301.7701(b)-7(b) and (c) require that... Read more →