Tax residence in the United States for Singapore taxpayers

The United States treats you as resident if you hold a green card or meet the substantial presence test over three calendar years, and it taxes its citizens wherever they live. Singapore decides your status for the calendar year by 183 days of presence or employment, normal residence of a citizen or PR, or IRAS's two- and three-year rules. There is no comprehensive income tax treaty between Singapore and the United States, so you can be resident in both, with no tie-breaker and no treaty rates.

Check your status: Singapore and United States

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of the United States and the tax treaty (DTA).

When United States treats you as a tax resident

The United States taxes its citizens on worldwide income regardless of where they live.

A green card makes you a U.S. resident for tax purposes even if you live abroad, until the status is revoked or abandoned.

The U.S. counts days over three years: all days in the current year, one third of the days in the previous year and one sixth of the days in the year before that.

You are a U.S. citizen — the United States taxes your worldwide income wherever you live, and a treaty tie-breaker does not change that (saving clause).
You held a green card this year — under § 7701(b) you are a U.S. resident regardless of how many days you spent in the United States.
Your weighted days over three years reach 183 — you meet the substantial presence test and are a U.S. resident.

When you are a non-resident

You do not meet the substantial presence test and have no green card — you are a nonresident alien. The U.S. taxes only your U.S.-source income and income connected with a U.S. business (including pay for work done in the U.S.).
Your days in the U.S. as a student, teacher, trainee or diplomat do not count — you are a nonresident alien.
Fewer than 183 days this year and a closer connection to another country (closer connection exception, Form 8840) — you are a nonresident alien.

Where the rules of the United States clash with Singapore tax rules

Collision: resident of both countries — no tie-breaker. The United States taxes you as a citizen, green-card holder or substantial-presence resident, and Singapore treats you as resident (183 days, normal residence of a citizen or Permanent Resident, or IRAS's two- and three-year rules). With no income tax treaty nothing resolves the conflict: you remain a full resident of both countries. In practice the overlap is narrow: Singapore taxes income received in or derived from Singapore, and foreign income received in Singapore by a resident individual is generally exempt (s. 13(7A)), except through a Singapore partnership. Double tax therefore falls mainly on Singapore-source income (pay for work done in Singapore, Singapore rents): Singapore taxes it as the source country, and the United States credits the Singapore tax or lets you exclude foreign earned income under § 911.
Collision: green-card holder resident in Singapore — no treaty to rely on. A green card makes you a U.S. resident for the whole year regardless of the days you spend in the United States. Where a treaty exists, a green-card holder can sometimes claim treaty residence in the other country; with no U.S.–Singapore treaty that route is closed, and the closer connection exception belongs to the substantial presence test, which does not apply to green-card holders. While you hold the green card the United States taxes your worldwide income and Singapore taxes you under its own rules; double tax is relieved only by the U.S. foreign tax credit or the foreign earned income exclusion. The status lasts until the green card is formally revoked or abandoned (Form I-407).
Substantial presence in the U.S. and residence in Singapore: only the closer connection exception helps. You are a U.S. resident only under the substantial presence test (weighted days over three years). With no U.S.–Singapore treaty you cannot claim treaty nonresidence under a tie-breaker. The only way out of U.S. residence is the closer connection exception: fewer than 183 days in the United States in the year, a tax home in Singapore for the whole year, a closer connection to Singapore than to the United States, a timely Form 8840, and no green-card application (e.g. Form I-485). If it applies, you are a nonresident alien taxed in the U.S. only on U.S.-source income and income connected with a U.S. business. In the year you arrive or leave you may be a dual-status taxpayer.

What else to know

U.S. citizens: the United States taxes you wherever you live. The United States taxes its citizens on worldwide income wherever they live, also while they are resident in Singapore. With no U.S.–Singapore treaty there is no tie-breaker and no treaty relief article: double tax is relieved only by U.S. rules — the foreign tax credit for Singapore income tax (Form 1116), capped at the U.S. tax on foreign-source income by category, or the foreign earned income exclusion of up to $132,900 for 2026 plus a housing amount if you have a tax home abroad and meet the bona fide residence or 330-day physical presence test (Form 2555). No credit is allowed for tax on excluded income.
Working in the U.S. as a nonresident: no treaty exemption. Wages for work done in the United States are U.S.-source income connected with a U.S. trade or business and are taxed at graduated rates on Form 1040-NR, even for a short assignment and even if a Singapore employer pays you — with no treaty there is no 183-day exemption. Pay for work done abroad is generally not taxed in Singapore unless it is incidental to a Singapore employment; whether Singapore then relieves the U.S. tax is not covered here.
U.S. investment income of a Singapore resident: 30% withholding, no treaty rate. As a nonresident alien you pay a flat 30% of the gross amount on fixed or periodic U.S. income — interest, dividends, rents, royalties — that is not connected with a U.S. business, usually withheld by the payer. With no U.S.–Singapore treaty there is no reduced rate for Singapore residents. Singapore generally exempts foreign-sourced income received in Singapore by resident individuals (s. 13(7A)), so the U.S. withholding is usually the final tax.
Students, trainees and researchers from Singapore in the U.S.. Days on an F, J, M or Q visa as a student, or on a J or Q visa as a teacher or trainee, are generally excluded from the substantial presence test, so you can stay a nonresident alien for years. With no U.S.–Singapore treaty there is no treaty exemption for scholarships, maintenance payments or teaching pay — U.S. law alone decides how they are taxed. Singapore decides your status for the calendar year under its own rules (s. 2(1) Income Tax Act 1947), whatever your U.S. status.
State income tax: domicile can follow you abroad. This assessment covers federal tax only. States set their own residence rules, and some keep taxing people who move abroad but remain domiciled there. California treats a domiciliary who is away for a temporary or transitory purpose as a resident (safe harbor: an employment contract abroad for at least 546 consecutive days, with limits) and allows no foreign earned income exclusion or foreign tax credit. New York taxes its domiciliaries unless an exception applies (e.g. 450 days abroad in a 548-day period). Check the rules of your last state.
No U.S.–Singapore social security (totalization) agreement. Singapore is not on SSA's list of U.S. social security agreements. U.S. Social Security and Medicare taxes (or self-employment tax) apply under U.S. law, no certificate of coverage can exempt you, and periods in the two countries are not added together.

How dual residence is resolved

There is no tax treaty (DTA) in force between Singapore and this country.

Terms you will come across in the United States

substantial presence test: U.S. residence by weighted days over the current and two previous years
green card test: a lawful permanent resident is a U.S. resident regardless of days
exempt individual: student, teacher, trainee or diplomat whose U.S. days are not counted
closer connection exception: Form 8840: nonresidence despite the day count, with a tax home abroad
Form 1040-NR: U.S. income tax return of a nonresident alien
foreign earned income exclusion: Form 2555: U.S. citizens abroad may exclude earned income up to an annual limit

Questions

Is there a tax treaty between Singapore and the United States?

No comprehensive one — only a limited 1988 agreement on income from international shipping and air transport. There is no tie-breaker, no 183-day rule for short assignments, no reduced withholding rates and no mutual agreement procedure.

I am a U.S. citizen living in Singapore. Do I still pay U.S. tax?

Yes. The United States taxes its citizens on worldwide income wherever they live; you relieve double tax with the foreign tax credit for Singapore tax or the foreign earned income exclusion. Singapore taxes mainly Singapore-source income and generally exempts foreign income received by resident individuals.

How are U.S. dividends taxed if I am resident only in Singapore?

As a nonresident alien you pay a flat 30% U.S. tax, usually withheld at source, with no treaty reduction. Singapore generally exempts foreign-sourced income received by resident individuals, so the U.S. withholding is usually the final tax.

Sources

Legislation and official guidance

Treas. Reg. § 1.1-1(b) — U.S. citizens, wherever resident, are liable to income tax on income from all sources.
26 U.S.C. § 7701(b) — An alien is a U.S. resident for a calendar year if he or she is a lawful permanent resident (green card) at any time in that year, meets the substantial presence test, or makes the first-year election.
Treas. Reg. § 301.7701(b)-1(b) — A lawful permanent resident (green-card holder) is a U.S. resident for the calendar year regardless of the number of days spent in the United States.
§ 7701(b)(3)(A); Treas. Reg. § 301.7701(b)-1(c) — Substantial presence test: at least 31 days in the current year and at least 183 days counting all current-year days, 1/3 of the days in the first preceding year and 1/6 of the days in the second preceding year. Fractions are not rounded.
26 U.S.C. § 7701(b)(5); 26 CFR § 301.7701(b)-3(b) (Treas. Reg.) — Days are not counted for 'exempt individuals': foreign-government-related individuals (diplomats), students on F, J, M or Q visas (generally up to 5 calendar years), teachers or trainees on J or Q visas (unless exempt in 2 of the prior 6 years), and professional athletes temporarily in the United States to compete in a charitable sports event (only the days of actual competition are excluded). The list of these four categories is exhaustive.
IRS Publication 519, U.S. Tax Guide for Aliens — Official IRS guide for aliens: residence tests, exempt individuals, closer connection exception, dual-status years, dual-resident taxpayers.
§ 7701(b)(3)(B)–(C); Treas. Reg. §§ 301.7701(b)-2, -8 — Closer connection exception: fewer than 183 days in the current year, a tax home in a foreign country for the whole year, a closer connection to that country, and a timely Form 8840; not available if you applied for a green card (e.g. Form I-485).
U.S. Model Income Tax Convention (2016), Art. 1(4)–(5) (saving clause) — The convention does not affect a state's taxation of its residents and its citizens, except for listed benefits (incl. relief from double taxation, non-discrimination, mutual agreement). Each actual treaty has its own saving-clause article — check the treaty with the other country.
IRAS — Singapore–United States limited agreement on income from shipping and air transport (1988) — Reciprocal exemption of income from the international operation of ships and aircraft; concluded and in force on 28 July 1988, applying to taxable years from 1 January 1987. It has no residence tie-breaker for individuals.
s. 2(1) Income Tax Act 1947 (definition of «resident in Singapore», para (a)) — An individual is resident in Singapore if, in the year preceding the year of assessment, he or she resides in Singapore except for such temporary absences as may be reasonable and not inconsistent with a claim to be resident; also resident is a person who in that year was physically present or exercised employment in Singapore (other than as a company director) for 183 days or more.
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
26 U.S.C. § 901(b)(1) — A U.S. citizen may credit income taxes paid or accrued to a foreign country (subject to the limitations of § 904).
26 U.S.C. § 911(a), (d)(1), (d)(6) — A qualified individual (tax home abroad and bona fide residence for an entire taxable year, or 330 full days abroad in 12 consecutive months) may elect to exclude foreign earned income and a housing amount; no foreign tax credit is allowed for taxes allocable to the excluded income.
26 U.S.C. §§ 901, 904; IRS — Foreign Tax Credit: how to figure the credit — The credit cannot exceed total U.S. tax multiplied by foreign-source taxable income over total taxable income; it is figured on Form 1116; unused foreign tax can be carried back to the previous year and forward 10 years.
IRS — Figuring the foreign earned income exclusion — Maximum exclusion: $130,000 for 2025 and $132,900 per person for 2026. Housing amount limitation (generally 30% of the maximum exclusion, adjusted by location): $39,000 for 2025, $39,870 for 2026.
26 U.S.C. §§ 871, 1441; IRS — Taxation of nonresident aliens — Income effectively connected with a U.S. trade or business (including wages for services in the U.S.) is taxed at graduated rates; fixed or periodic income (interest, dividends, rents, royalties) not effectively connected is taxed at a flat 30% of gross unless a treaty sets a lower rate; return: Form 1040-NR.
IRAS — «Claiming foreign tax credit» — Where foreign income is taxable in Singapore and foreign tax has been paid on it, a resident can claim a foreign tax credit in the return; the credit is the lower of the foreign tax paid and the Singapore tax payable on that income.
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
California FTB Publication 1031 (2025), Guidelines for Determining Resident Status — Resident: present in California for other than a temporary or transitory purpose, or domiciled in California but outside for a temporary or transitory purpose. Safe harbor for domiciliaries abroad under an employment-related contract for at least 546 consecutive days (return visits up to 45 days, intangible income not over $200,000, no tax-avoidance purpose). California allows no foreign tax credit and no foreign earned income exclusion.
New York State DTF — Personal income tax definitions (domicile, resident) — A New York domiciliary is a resident unless the conditions of Group A or Group B are met; Group B: at least 450 days in a foreign country during any 548 consecutive days, with you and your household spending 90 days or less in New York in that period (plus a prorated limit).
SSA — U.S. international social security agreements (status)
26 U.S.C. § 1411; IRS — Questions and Answers on the Net Investment Income Tax — 3.8% on net investment income above MAGI of $200,000 (single), $250,000 (married filing jointly), $125,000 (married filing separately); amounts excluded under § 911(a)(1) are added back to MAGI; nonresident aliens — including dual residents claiming treaty nonresidence — are not subject.

Case law

United States Tax Court, Topsnik v. Commissioner, 146 T.C. No. 1 (docket 2482-14), 20/01/2016 — Lawful permanent resident status continued until it was formally abandoned (Form I-407); the taxpayer could not rely on German residence under the treaty because he was not liable to tax in Germany on his worldwide income.

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

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