🇯🇵 Japan vs 🇺🇸 United States

Tax residency, treaties and PE risk compared.

Dimension🇯🇵 Japan🇺🇸 United States
Residency ruleJusho (domicile) + 1-year presenceCitizenship-based + Substantial Presence
Day threshold365 days183 days
Warning bandfrom 183dfrom 122d
Tax range5–45% + 10% local10–37% federal + state
Tax treaties85+70+
PE riskMediumHigh
Digital nomad visaYesNo
Best forNon-permanent residents (first 5 of 10 years) shielding foreign incomeUS citizens optimising via FEIE ($126,500) and treaty benefits
Common pitfallNon-permanent resident status ends after 5 years — then worldwide tax kicks in.US citizens are taxed on worldwide income forever — there is no day-count exit.

Verdict

For most nomads optimising for residency safety, 🇯🇵 Japan is the lower-risk base versus 🇺🇸 United States. United States's high PE risk and 183-day rule make it easier to trip into full residency.

Deep dive

🇯🇵 Japan residency rules →

Deep dive

🇺🇸 United States residency rules →

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