🇺🇸 United States vs 🇯🇵 Japan

Tax residency, treaties and PE risk compared.

Dimension🇺🇸 United States🇯🇵 Japan
Residency ruleCitizenship-based + Substantial PresenceJusho (domicile) + 1-year presence
Day threshold183 days365 days
Warning bandfrom 122dfrom 183d
Tax range10–37% federal + state5–45% + 10% local
Tax treaties70+85+
PE riskHighMedium
Digital nomad visaNoYes
Best forUS citizens optimising via FEIE ($126,500) and treaty benefitsNon-permanent residents (first 5 of 10 years) shielding foreign income
Common pitfallUS citizens are taxed on worldwide income forever — there is no day-count exit.Non-permanent resident status ends after 5 years — then worldwide tax kicks in.

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

🇺🇸 United States residency rules →

Deep dive

🇯🇵 Japan residency rules →

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