IRS Issues New Guidance Addressing COVID- 19 Travel Disruptions and the Impact on U.S. Tax Residency

Lisa Goldman, CPA, TEP, M.Tax | Rebeccah Fontaine, J.D., LL.M of Berdon LLP Beth Tractenberg, J.D. | Zvi Hahn, J.D., LL.M, LL.B. | George McCormick, J.D., LL.M. of Steptoe & Johnson LLP
In our recent advisory—COVID-19 and the Unintended Resident; the Good, the Bad, and the Ugly— we alerted non-U.S. citizens unable to leave the United States due to COVID-19 travel disruptions of the potential tax implications of their unintended stay in the country. The IRS apparently heard the call and recently issued Revenue Procedure 2020-20 that provides guidance and relief for foreign individuals and corporations as it pertains to U.S. tax residency.