For a non-resident acquiring a green card, foreign unearned income deriving from what date is subject to U.S. global income and capital gains taxation:
1) January 1st (tax year) of the year the Green Card is issued. (Applicant is not present in the U.S.)
2) January 1st (tax year) of the year non-resident applicant enters the U.S. on the green card visa.
3) The exact date the Green Card is issued. (Therefore only a portion of income of that tax year will be subject to global taxation)
4) The exact date the non-resident applicant enters the U.S. on the green card visa. (ditto)
5) Something else?
P.S. I explicitly stated unearned income so as not to confuse any extended-applicability of the Foreign Earned Income exemption. Think for example, when should you sell your house, or shares in a foreign company, without subjecting the transaction(s) to U.S. capital gains tax. No double-tax treaties.
1) January 1st (tax year) of the year the Green Card is issued. (Applicant is not present in the U.S.)
2) January 1st (tax year) of the year non-resident applicant enters the U.S. on the green card visa.
3) The exact date the Green Card is issued. (Therefore only a portion of income of that tax year will be subject to global taxation)
4) The exact date the non-resident applicant enters the U.S. on the green card visa. (ditto)
5) Something else?
P.S. I explicitly stated unearned income so as not to confuse any extended-applicability of the Foreign Earned Income exemption. Think for example, when should you sell your house, or shares in a foreign company, without subjecting the transaction(s) to U.S. capital gains tax. No double-tax treaties.