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One must be a citizen or domiciliary (intent and presence plus facts and circumstances) to be subject to US transfer tax while simply spending one too many days in the US may subject you to US income tax.
FORBES: Renouncing One's US Citizenship -- Meaningful Trend Or Visceral Overreaction?
Goosen has a residence in England and as a non-domiciliary U.K. resident wanted to claim benefits under the U.S.-U.K. tax treaty.
FORBES: Tax Court to Athletes: Image Isn't Everything But It's At Least 50%
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