San Diego Law Review

Library of Congress Authority File


Document Type



This Comment examines this issue of taxation of nonresident aliens. The author argues that nonresident aliens have varying degrees of activity in the United States because of business, family, or tourism. When this level of activity is of the requisite nature, an alien can be classified as a resident for United States income tax purposes, and that different treatment under the tax laws of residents and nonresidents makes this distinction important. The author examines income tax planning for the nonresident alien, who is married to a citizen or resident of the United States, and for the nonresident alien, who is about to become or who has become a resident alien and who has nonresident family members.