The Core: retiring abroad on US income · Module 1 · about 6 minutes

C1 The four kinds of "residence"

Your visa, your tax residence, your US state and your Schengen days are four separate tests, and they can point in four directions.

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Concept

Most people use "resident" as if it meant one thing. Abroad it means at least four, and each is decided by a different authority with a different test:

Kind of residence	Who decides	What it decides	The usual test
Immigration status	The country's immigration office	Whether you may stay, and for how long	The visa or residence card you hold
Tax residence	The country's tax office	Whether it taxes your worldwide income	Days present, where your home and family are, where your money is managed
US state domicile	Your US state	Whether the state taxes you	The place you intend to return to and treat as home
Schengen days	Border police	How long a visitor may stay	90 days in any 180, across all Schengen countries

They are independent. You can hold a residence card and not be tax resident (Portugal's investment visa needs only a few days a year). You can be on a visitor visa and be fully tax resident (France's visitor visa is the usual retirement route, and its holders usually become French tax residents). And the US taxes its citizens wherever they live, so none of these changes whether you file a US return.

When two countries both say you are their tax resident, the tax treaty between them has a tie-breaker. It asks, in order: where do you have a permanent home available? If both, where is the centre of your vital interests (family, social life, money)? If that's unclear, where do you habitually live? Then citizenship. For an American, the tie-breaker settles which country has the first right to tax most income, and which one gives the credit. It does not take you out of the US system.

What people miss

Days are only one test. Staying under 183 days doesn't on its own keep you non-resident. Spain presumes you're resident if your spouse and minor children live there; France looks at where your household is; Portugal looks at whether you keep a home you plan to live in.
A visa is not a tax status. A long-stay visa lets you stay past 90 days. It doesn't decide where you pay tax, but applying for one is evidence that you plan to live there.
Schengen counts across countries. Ninety days in France plus two weeks in Italy is over the limit, even if you never spent 90 days in either.
Arrival and departure days both count for Schengen. A trip from 3 January to 2 April is 90 days, not 89.

Worked example

Mike and Linda Ortiz (both 67) keep their house near Chicago and want to spend January through April in Nice, as visitors with no French visa.

From 3 January to 30 April is 118 days in France. That is well under 183, so France's day test is not met, and the Ortizes keep their US home, their doctors and their bank accounts in Illinois, so France's other tests point to the US too. But 118 days breaks the Schengen limit: as visitors they must leave by 2 April (90 days), or get a long-stay visa first.

Their choice is really between two questions, which this course keeps separate: how long may we stay (immigration and Schengen), and will we owe France tax (tax residence)? A four-month visitor visa answers the first. Keeping their life centred in Illinois answers the second.

Your numbers

Log your trips below. The counter checks the Schengen limit, each country's 183-day test and your days in the US. If you hold a long-stay visa or residence card, choose its country: days there don't count toward 90/180.

Your trips

One row per stay outside the US: where, the day you arrived and the day you left. Both days count. Days with no trip are counted as days in the US.

Where	Arrived	Left

To remove a trip, clear both its dates.

Year to check

Residence permit or long-stay visa

Days in the country that issued it don't count toward 90/180.

Planning date

See your Schengen days on this date, and how long you could stay from it.

Schengen 90/180 in 2026

Within the limit. Your busiest 180 days held 80 of 90 allowed days (on 28 Mar).

On 26 Oct 2026 you have used 36 days of the last 180, with 54 left. Arriving that day and staying in a country that counts, you could stay until 18 Dec 2026.

Tax-residence day tests

Country	Days counted	Line	Status
Spain	80	over 183	Under More than 183 days in Spain in the calendar year (sporadic absences can count as days in Spain).
Portugal	36	over 183	Under More than 183 days in Portugal in any 12-month period that starts or ends in the tax year. Busiest 12 months: 21 Oct 2025 to 20 Oct 2026 (36 days in 2026).
France	0	over 183	Under Your main place of stay is France. More than 183 days in France in the calendar year is the usual sign of that, but it is an indicator rather than a strict count.

241 of 365 days in the US, 8 outside Schengen.

Days in each place, month by month. A travel day between two places counts in both.

Days are only part of the test

Staying under 183 days does not on its own keep you out of a country's tax system. Each country also looks at where your life is centred:

Spain: Your main base of business or economic interests is in Spain. Presumed resident if your spouse (not legally separated) and dependent minor children live in Spain.
Portugal: Having a home in Portugal on any day of that period, in conditions suggesting you intend to keep it as your habitual residence.
France: Your household (foyer) lives in France, even if you spend less time there. Your main professional activity is in France. The centre of your economic interests is in France. Any one of these tests on its own makes you resident.

And the US taxes its citizens wherever they live, so US tax returns continue either way.

Create a free account to keep your trip log. Without one, nothing you type is saved.

Check with an adviser

Which tie-breaker tests a tax adviser in your destination would apply to your facts (home, family, money), not only your day count.
If you hold a long-stay visa or residence card, whether the consulate or tax office treats it as a sign you mean to live there.

Sources

Worked examples use 1 EUR = 1.12 USD so the numbers stay fixed; the calculators use today's rate (1.1193).