Hi @pk, regarding the points you raised, I am responding to them in that order. Before all that, I must say that I am totally fine paying the retroactive tax and I think it is only fair.
1.) It is the risk that researcher took in availing the treaty benefits. So, it can reap rewards if they finish their work before 2 years or they have to save up for the retroactive tax, knowing that they may have to extend for some reason. I do not consider this as a negation to the intent behind the treaty.
2.) Regarding the interest on late payment (which is again only fair), I cannot find any information regarding anywhere. But I was just hoping this is more streamlined like for instance, some form that takes care of this.
2.) I agree suspending saving clause in my case, does not necessarily mean retroactive tax due to the use of the phrase "MAY" in Article 22.
I agree with you on considering pros and cons. I also read online that late fee can be waived by the IRS depending on the case at hand. Finally, If I amend my 2022 and 2023 returns, will it affect only my 1040-NR?
Thank you.
