Exception:
Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States
Applicants who hold green cards as commuters from Canada or Mexico. For U.S. Income tax purposes, individuals with commuter green cards are U.S. residents taxable on their worldwide income.
Have been in the United States at least 31 days during the current year and 183 days during the period that includes the current year and the 2 years immediately preceding the current year, counting each day during the first preceding year as 1/3 of a day, and each day in the second preceding year as 1/6 of a day (See Pub 519, U.S. Tax Guide for Aliens, to apply the Substantial Presence Test.)
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