All treaty guides

U.S.-abroad tax field guide

Moving to Costa Rica: treaty and U.S. state-residency checklist

Costa Rica does not appear in the IRS A-to-Z list of U.S. income-tax treaties. That makes domestic law, income sourcing, and available U.S. relief mechanisms especially important.

Treaty status: No comprehensive income-tax treaty

Treaty status is the beginning of the analysis, not the conclusion. Confirm residence under domestic law, identify the exact income article, read protocols and technical explanations, then test the saving clause and its exceptions.

What to examine in the treaty layer

  • Do not rely on a treaty tie-breaker or treaty rate without first verifying that a relevant agreement exists.
  • Foreign tax credit analysis can still matter even when there is no comprehensive income-tax treaty.
  • Information exchange, Social Security, or other bilateral agreements are not the same as a comprehensive income-tax treaty.

The U.S. federal layer still exists

Worldwide-income filing

U.S. citizens generally file on worldwide income while abroad, subject to applicable exclusions, credits, deductions, and treaty provisions.

Foreign tax credit

A credit may relieve double taxation of qualifying foreign income taxes, but baskets, sourcing, carryovers, and limitations matter.

FEIE

The exclusion requires a foreign tax home plus the bona fide residence or physical presence test; moving abroad by itself is not enough.

Information reporting

FBAR, Form 8938, and entity, trust, gift, or pension forms are separate questions and can apply even when no U.S. income tax is due.

The state-residency layer

A U.S. treaty is federal. Your former state can apply its own domicile and statutory-residency rules. A flight, foreign visa, or federal foreign-residence claim does not automatically end state residence.

  • Document intent and conduct: when you left, where you established a permanent home, and the facts showing where you intend to return.
  • Inventory retained ties: homes, spouse or dependents, licenses, voting, vehicles, business interests, professional licenses, mail, and time in the state.
  • Check a separate day/abode test: some states can treat a domiciliary nonresident as resident under a statutory test.
  • Use filing-year instructions: part-year and nonresident filing, state-source income, and safe-harbor rules can change.

Costa Rica pre-move questions

  1. 1Confirm Costa Rican tax residence, registration, and territorial-source treatment under current local law.
  2. 2Classify work performed while physically in Costa Rica and document who pays it and where services occur.
  3. 3Ask a cross-border adviser how mismatches are handled without a comprehensive treaty framework.
Build an interactive checklist →

Official sources

Accessed October 1, 2026. Re-open the live source and current filing-year instructions before acting.

Educational only. This guide does not determine tax residence, treaty eligibility, domicile, filing status, or tax owed, and is not tax, legal, financial, or accounting advice. Use qualified advisers in the United States and Costa Rica.