[hotspot_one]

> If I’m employed in my home country, earning money there and paying taxes, what difference does it make if I happen to sit in another country?

Why does "home country" have tax priority over "sitting in" country? How does that make sense vs having the taxes paid in "sitting in" country instead of "home country"?

with perhaps the strongest argument being jurisdiction. What gives "home country" the legal right to claim taxes on income earned in "sitting country"?

and that's where things get complicated. In order to pay taxes in "sitting country" you need a "sitting tax ID number" and other admin, also if the taxes involve wage withholding, who does the withholding and ensures compliance, etc, etc.

How does this align, in the US, with state-level taxes? If you were born in MN and moved to FL, do you pay MN or FL state income taxes (noting that FL does not have state income tax)?

Is "home country" the state with the home office of the company which employs you, or the state you live in? Should employees of a California company pay California state income tax even when working remote from Texas (another no income tax state)? Or the classic Washington/Oregon divide?

[chrisfosterelli]

> with perhaps the strongest argument being jurisdiction. What gives "home country" the legal right to claim taxes on income earned in "sitting country"?

Usually a treaty. At least here in Canada the government has tax treaties with most other countries whereby both countries agree the citizen should pay taxes to the country they reside in the majority of the year.

[junar]

The relevant portion of the US-Japan treaty is Article 14(2). As the IRS explains:

> Paragraph 2 sets forth an exception to the general rule in paragraph 1 that employment income may be taxed in the Contracting State where the employment is exercised. Under paragraph 2, the Contracting State where the employment is exercised may not tax the income from the employment if three conditions are satisfied: (1) the individual is present in the other Contracting State for a period or periods not exceeding 183 days in any 12-month period that begins or ends during the relevant (i.e., the year in which the services are performed) calendar year; (2) the remuneration is paid by, or on behalf of, an employer who is not a resident of that other Contracting State; and (3) the remuneration is not borne by a permanent establishment that the employer has in that other Contracting State. In order for the remuneration to be exempt from tax in the source State, all three conditions must be satisfied. This exception is identical to that set forth in the U.S. and OECD Models.

https://www.irs.gov/pub/irs-trty/japante04.pdf

https://www.mof.go.jp/tax_policy/summary/international/tax_c...