Serbinski Accounting Firms

My, uh, friend thanks you for your reply, but has two questions: which paragraph(s) of Article XXV do you rely on for this conclusion, and can FEIE/FTC be used by Dave in this case? By my reading, paragraph 1 applies to Alice, but only to the extent that if 6013(g) were restricted to US citizens and...

My friend Alice is a Canadian citizen living and working in the US, while her husband Dave lives and works in Canada. Alice meets the substantial presence test and tie-breaks to US, whereas Dave is not a US person for tax purposes. It's well-documented in IRS Publication 519 that Alice can file as M...