In Part Two, Greenspoon Marder attorneys Hector Chichoni and Ruben Gottlieb dive deeper into the complex concepts of U.S. tax residency, domicile, and how intent can trigger significant income, gift, and estate tax consequences. With an eye toward planning for 2026 and beyond, they break down the mechanics of the substantial presence test, explains how day‑counting really works, and outlines the limited exceptions available through tax treaties and the IRS “closer connection” framework. The conversation reinforces why income tax residency and estate and gift tax domicile are governed by entirely different legal standards and why confusing the two can be costly.

The episode also explores how immigration milestones such as filing an I‑140, adjustment of status, or entering the U.S. on a green card can have immediate and sometimes retroactive  ...