If an individual has submitted a statement of nonresidence to the authorities of a foreign country the accuracy of which has not been resolved as of any date when a determination of the individual's bona fide residence is being made, then the individual will not be considered a bona fide resident of the foreign country as of that date.
Country | Time and date of arrival | Time and date of departure | Full days in foreign country |
United States | 10 p.m. (by air) Mar. 5, 1982 | ||
United Kingdom | 9 a.m. Mar. 6, 1982 | 10 p.m. (by ship) June 25, 1982 | 110 |
United States | 11 a.m. June 30, 1982 | 1 p.m. (by ship) July 19, 1982 | 0 |
France | 3 p.m. July 24, 1982 | 11 a.m. (by air) Aug. 22, 1983 | 393 |
United States | 4 p.m. Aug. 22, 1983 | 9 a.m. (by air) Sept. 4, 1983 | 0 |
United Kingdom | 9 a.m. Sept. 5, 1983 | 9 a.m. (by air) Jan. 1, 1984 | 117 |
United States | 1 p.m. Jan. 1, 1984 |
Among other possible twelve-month periods, C is present in a foreign country or countries an aggregate of 330 full days during the following twelve-month periods: March 2, 1982 through March 1, 1983; and January 21, 1983 through January 20, 1984. The computation of days with respect to each twelve month period may be illustrated as follows:
First twelve-month period (March 2, 1982 through March 1, 1983):
Full days in foreign country | |
Mar. 2, 1982 through Mar. 6, 1982 | 0 |
Mar. 7, 1982 through June 24, 1982 | 110 |
June 25, 1982 through July 24, 1982 | 0 |
July 25, 1982 through Mar. 1, 1983 | 220 |
Total full days | 330 |
Second twelve-month period (January 21, 1983 through January 20, 1984):
Full days in foreign country | |
Jan. 21, 1983 through Aug. 21, 1983 | 213 |
Aug. 22, 1983 through Sept. 5, 1983 | 0 |
Sept. 6, 1983 through Dec. 31, 1983 | 117 |
Jan. 1, 1984 through Jan. 20, 1984 | 0 |
Total full days | 330 |
26 C.F.R. §1.911-2
Sec. 911 (95 Stat. 194; 26 U.S.C. 911 ) and sec. 7805 (68A Stat. 917; 26 U.S.C. 7805 ) of the Internal Revenue Code of 1954