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World bank income


Pacun

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Venezuelan got advance parole in Colombia and was sponsored by one of his clients. The world bank gave him a job upon arrival and he made $35K.  To me he has to file taxes, but he has consulted with the "tax department" of the world bank and has been told that ONLY US Citizens and Legal Permanent Resident ("green card holders") are required to pay taxes on world bank income. 

That's is correct but the way I interpret it is: If you have a G4 visa through the world bank, the income is not taxable. 

Any suggestions? I do believe he has to file but my world against the HR department and "tax department" from the world bank is weak. 

 

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What is his residency or visa status?

Perhaps see: https://www.irs.gov/individuals/international-taxpayers/employees-of-foreign-governments-or-international-organizations

You should read it all, but highlights are:

Quote

Many agreements that establish international organizations contain a provision that may exempt your compensation from U.S. income tax. If you are employed by an international organization in the United States, first look to see if the international agreement establishing the international organization you are employed by has such a provision and whether you qualify under it. Generally, these provisions will not exempt compensation of U.S. citizen and resident alien employees.

...

If the international agreement creating the international organization you are employed by does not contain a tax exemption provision and you are not a U.S. citizen (or if you are a U.S. citizen but also a citizen of the Republic of the Philippines), you may be able to exempt your compensation under U.S. tax law. To claim the exemption, you must be able to demonstrate that you meet the requirements of U.S. tax law. ...

 

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The organization clearly has its income exempted if you are NOT a us citizen or resident. He is a resident based on the days he has being in the US since he doesn't hold a G4 visa, which pretend that you don't "exist" in the US. I am going to send my question to NATP research team and see what they say. 

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  • 2 weeks later...

 

If your client is not a World Bank employee exempt from US tax, even though he is not a US citizen or green card holder, if they are present in the US for more than 183 days, they are considered as US residents for tax purposes by meeting the Substantial Presence Test SPT. Therefore, they are required to report worldwide income on his US return. Substantial Presence Test | Internal Revenue Service (irs.gov)

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