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A special anti-avoidance provision, IRC 877, applies to certain former U.S. resident aliens who temporarily convert to U.S. income tax nonresident alien status (by failing

A special anti-avoidance provision, IRC 877, applies to certain "former" U.S. resident aliens who temporarily convert to U.S. income tax nonresident alien status (by failing both the permanent resident alien green card test and the physical days substantial presence test). If A, who spent 183 days or more in each of 2020, 2021, and 2022 in the U.S. and was a resident alien for each of those years, now wishes to avoid the application of IRC 877, A must maintain U.S. income tax nonresident alien status through:

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2023

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2024

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