Moving to the US at end of the year - Taxes

[European]

Hi all,
Imagine you currently live in UAE, a tax resident there and have a company in a Free zone. Let's say to start that you are the sole shareholder.
You move to the US in September or October 2023 with the intention to work and live there for a couple of years.

1) Would you be liable for tax only in the US only for the income you have earned in the US in 2023?
2) What happens if you keep the company operating until the end of the year? Is it taxable in the US?
3) What if you keep the company operating after Jan 2024? (I guess it will then be fully taxable in the US in 2024)

 

[Larin]

Hi all,
Imagine you currently live in UAE, a tax resident there and have a company in a Free zone. Let's say to start that you are the sole shareholder.
You move to the US in September or October 2023 with the intention to work and live there for a couple of years.

If that is your intention you become a tax resident in the US on the day you landed at the airport.

1) Would you be liable for tax only in the US only for the income you have earned in the US in 2023?

Taxation of Dual-Status Aliens | Internal Revenue Service

You are a dual-status alien when you have been both a resident alien and a nonresident alien in the same tax year.

www.irs.gov

You become liable for all income earned world wide from the day you become a tax resident in the US.

2) What happens if you keep the company operating until the end of the year? Is it taxable in the US?

Will the company retain any earnings or distribute it?
Here are the relevant (US CFC) rules: Controlled Foreign Corporation (CFC) - Who is Subject to Taxation? - US Tax & Financial Services

3) What if you keep the company operating after Jan 2024? (I guess it will then be fully taxable in the US in 2024)

See above.

 

[JustAnotherNomad]

Who operates the company in Dubai? It would probably (I'm not a lawyer/accountant) be ETBUS if you are in any way involved with it after you are tax resident in the US, so it would have to pay tax in the US, even if it's not a CFC.