I thinkāand Iām not sure about thisāthat the IRA withdrawals will be taxable as other income in the country of āresidenceā as determined under the treaty, and also taxable in the US under the savings clause. So post-NHR you might be facing 48%, with much less available as a credit to reduce US taxes.
That is one reason why some people are focusing on high withdrawals while NHR is in place, post -59-1/2. Max them out at 24 or 32%, with the 10% as a credit against the US taxes.
Well, if your scenario is truly correct, I might have to become Nevada, Texas, or Florida resident and tax resident againā¦ 
I will investigate this issue with my accountant here in PT.
I am definitely planning to domecile outside california before leaving the country. No thanks, CA taxes for no benefit!
Wait, do you keep getting taxed in the state you last lived in even if you permanently move to PT? Like, forever?
No, you donāt. However, even if you move to Antarctica to teach penguins how to fly, you are still responsible for paying the U.S. Federal taxes.
What I meant was that if after the end of NHR it wouldnāt make financial sense to keep declaring myself PT tax resident (i.e. 183+ days here), I would always have an option to āmoveā to a tax-free state in the U.S. and claim the tax residency there, alerting PT that I am no longer PT tax resident.
That was one question I had, whether the NHR election was revocable. Sounds like it is?
Yes, and I understand you can also suspend it (though not recommended the first year). This doesnāt stop the 10 year period from running, but I believe would opt you out of your reporting obligations.
That would be helpful for someone, like me, who would make the election on the possibility (not yet known) if I would actually move there. Would be great to have it be suspended entirely until such time as you actually move there. Will confirm with tax lawyer.
It depends on the state. A few of them are famously aggressive about this (CA, NY come to mind). For that reason itās advisable to change your US residency to a tax friendly state on your way out the door. We moved to Florida for a brief stint, for this reason.
You donāt need to ārevokeā NHR. If you want to stop being tax resident of Portugal, you need to notify FinanƧas of your decision. Thatās irrespective of your NHR status.
Thatās super helpful. Thank you.
Do you (or anyone else) know if I have until 31 December 2024 to apply for this?
Exactly my point!
You donāt revoke NHR. Using it is optional. In some cases it could result in a higher tax.
But itās only optional in theory, right? Once someone opts to use it, they cannot opt out of it one year and back in another, I am assuming.
My understanding is you can. What gets you into trouble is changing residency status. But I canāt say for sure.
Once you start NHR, it lasts for 10 years. Whether or not you need to file PT taxes during this period (if, for example, you move back to US for three years and do not spend 183+ days in PT) is independent of your NHR status. You donāt āopt outā or āopt inā of NHR anymore, just whether or not you need to file PT taxes due to your tax residency status.
183+ days spent in PT is irrelevant when it comes to filing PT tax return or not.
If you have your PT NIF registered with a PT postal address, then you must file a PT return annually (IRS) unless these two conditions are met:
I imagine none of the primary GV applicants would meet these both, hence filing a PT tax return for them is mandatory, no matter if you stay 183+ days in PT or not, you file IRS by Jun 30th.
However, some GV dependants may quite well be āno-income/no-bankā so for them it would not be necessary to file.
One last point to mention, it is possible to file a one joint application for the whole family unit, e.g. GV primary applicant files his/her IRS and includes all GV dependants on it.
If one is a GV investor, does one still have to have an address in Portugal to apply for NHR?
More than an address. You have to declare yourself fiscally resident at that address ( no fiscal representative) and trigger tax filing. Whether you use NHR and what the applicable DTT says are different questions.