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Cross-Border Tax-Related COVID-19 Relief 

by Henry Bubel, Jenny Longman, Tiffany Tam

Published: May, 2020

Submission: June, 2020


On April 21, 2020, the IRS released a much-awaited package of guidance in the cross-border tax space that provides relief to those impacted by the COVID-19 pandemic. The guidance relates to (1) day-counting for both tax residency purposes and certain treaty positions, (2) the ability of taxpayers to claim the foreign-earned income exclusion, and (3) carrying on a U.S. trade or business. The summary below provides an overview of this guidance, which has been issued in a combination of IRS Revenue Procedures and a “Q&A” available on the IRS website.

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