A client has a meeting with you and seeks advice on whether they are subject to tax in the USA or not. They tell you that they were born and raised in Germany, they visited South Beach and they rented a home and loved the South Florida sunshine. They are not USA citizens, they do not have a Green Card, but they did spend the following days in the USA: For 2020 they were physically present in the USA for 190 days, for 2019 they were physically present in the USA for 120 days and for 2018 they were physically present in the USA for 90 days. They earned no money during their stay in the USA but heard that the USA days should be very important in determining their USA tax situation.

Can you explain the USA tax residency rules and advice them as to their USA tax situation for the 2020?