Introduction And Residence
Generally speaking, the US is not an attractive location for resident expatriate executives seeking to limit taxation.

Taxation Of Resident Alien
Tax-resident foreign nationals in the US are taxed just about on the same basis as a US national.

Taxation Of Non-Resident Aliens
The US tax position of a non-resident alien is reasonably favourable.

Tax Treaties
A resident or nonresident alien from a country with which the United States has an income tax treaty may qualify for certain benefits.

Services For Foreign Employer
If a non-resident alien is paid by a foreign employer, his or her US source income may be exempt from US tax.

Social Security And Medicare Taxes
Resident aliens, in general, have the same liability for Social Security/Medicare Taxes as US citizens.

Totalization Agreements
TheUS has agreements with some foreign countries to avoid double payment of social security taxes.

Information provided on this site is for general guidance only and is often simplified. Actual IRS procedures are complex, and taxpayers should obtain professional assistance or use IRS sources for complete information.

Social Security And Medicare Taxes

Resident aliens, in general, have the same liability for Social Security/Medicare Taxes as US citizens. Non-resident aliens, in general, are also liable for Social Security/Medicare Taxes on wages paid to them for services performed by them in the United States, with certain exceptions based on their non-immigrant status. The following classes of non-immigrants and nonresident aliens are, at the time of writing, exempt from Social Security and Medicare taxes:

• A-Visas. Employees of foreign governments are exempt on salaries paid to them in their official capacities as foreign government employees. The exemption does not automatically apply to servants of employees of such foreign governments, not does it apply to spouses and children unless they are employed by a foreign government.
• D-visas. Crew members of a ship or aircraft may be exempt if the vessel is a foreign vessel and the employer is a foreign employer, or if the services are performed outside of the United States
  Crew members of an American vessel or aircraft who perform services within the United States are subject to Social Security and Medicare taxes. Crew members of an American vessel or aircraft who perform services outside the United States are subject to Social Security and Medicare taxes if the employee signed on the vessel or aircraft in the United States, or the employee signed on the vessel or vessel outside the United States but the vessel or aircraft touches a US port while he is employed thereon.
• F-visas, J-visas, M-visas, Q-visas. Non-resident alien students, scholars, professors, teachers, trainees, researchers, physicians, au pairs, summer camp workers, and other aliens temporarily present in the United States in F-1,J-1,M-1, or Q-1/Q-2 nonimmigrant status are exempt on wages paid to them for services performed within the United States as long as such services are allowed by USCIS for these nonimmigrant statuses, and such services are performed to carry out the purposes for which such visas were issued to them.
• G-visas. Employees of international organizations are exempt on wages paid to them for services performed within the United States by employees of such organizations. The exemption does not automatically apply to servants of employees of such international organizations, and does not to spouses and children unless they are employed by an international organization.
• H-visas. Exemptions apply to H-2 non-immigrants who are residents of the Philippines and who perform services in Guam; and to H-2A nonimmigrants admitted into United States temporarily to do agricultural labor.

However, foreign scholars, teachers, researchers, trainees, physicians, au pairs, summer camp workers, and other non-students in J-1, Q-1 or Q-2 nonimmigrant status who have been in the United States more than two calendar years are resident aliens and are liable for social security/Medicare taxes. When measuring an alien’s date of entry for the purposes of determining the five calendar years or the two calendar years mentioned above, the actual date of entry is not important. It is the calendar year of entry which is counted toward the two or five calendar years respectively. Thus, for example, a foreign student who enters the United States on December 31, 1998 counts 1998 as the first of his five years as an "exempt individual."

Further information on the tax treatment of special categories of alien workers can be found here.

The Tax Code provides a further exemption from social security/Medicare taxes for all students, American and foreign, known as the "student FICA exemption", under Revenue Procedure 2005-11.

The Heroes Earnings Assistance and Relief Tax (HEART) Act 2008 was directed at serving military personnel, but contained a provision requires US employers doing federal contract work for the US government, and using foreign subsidiaries to compensate their US employees working abroad, to begin paying Social Security and Medicare taxes on behalf of these employees. The provision is designed to make sure that defense contractors in Iraq, Afghanistan and elsewhere meet their legal obligation to pay payroll taxes on behalf of the people who work for them.

“For the sake of transparency and fairness in our tax system, we cannot allow Federal contractors to set up shell corporations in tax shelters and shirk their responsibility to pay payroll taxes for their American employees," Obama commented following approval of the legislation by the House of Representatives on 21st May.

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Introduction And Residence
Generally speaking, the US is not an attractive location for resident expatriate executives seeking to limit taxation.

Taxation Of Resident Alien
Tax-resident foreign nationals in the US are taxed just about on the same basis as a US national.

Taxation Of Non-Resident Aliens
The US tax position of a non-resident alien is reasonably favourable.

Tax Treaties
A resident or nonresident alien from a country with which the United States has an income tax treaty may qualify for certain benefits.

Services For Foreign Employer
If a non-resident alien is paid by a foreign employer, his or her US source income may be exempt from US tax.

Social Security And Medicare Taxes
Resident aliens, in general, have the same liability for Social Security/Medicare Taxes as US citizens.

Totalization Agreements
TheUS has agreements with some foreign countries to avoid double payment of social security taxes.