Hello,
I am a Portuguese citizen, resident in switzerland on a B-permit, moving to the US for 2 years on a J1 on a EU-funded postdoctoral fellowship (MSCA). During the fellowship my contract and income will be through an Italian institution. I am moving directly from Switzerland to the US, and after the US phase to Italy.
As I understand, during the US phase, I will be a
- non-resident allien in the US
- a non-resident but potentially taxable in Italy
- my swiss residency may cease.
I wonder if I can claim a tax treaty to avoid double taxation in the US, and if so, which one?
From my understanding the Swiss-US tax treaty could cover me even if I lose swiss residency, as it mentions:"Payments which a student, apprentice, or business trainee, who is or was immediately before visiting a Contracting State a resident of the other Contracting State, and who is present in the first-mentioned State for the purpose of his full-time education or training, receives for the purpose of his maintenance, education or training shall not be taxed in that State provided that such payments arise from sources outside that State"
On the other hand, I am unsure whether the Italy-US tax treaty could be evoked. Although there is a clause for researchers and professors, from my understanding, it is only valid for people who are considered residents in either one or both countries.
Would highly appreciate any help!!
Best,
Guilherme Almeida
