US Citizens Living in Georgia: Taxes in Both Countries

An American in Tbilisi answers to two tax authorities, and neither one cancels the other. Georgia taxes you on where you are and where your income comes from. The United States taxes you because of your passport. What Georgia reaches, what the IRS still wants, and whether a treaty sits between them are separate questions, and becoming a Georgian tax resident answers only the first.

You file in two places, for two different reasons

Georgia taxes individuals on residence and on source. Income of a resident individual that is not Georgian-source income is exempt under Article 82(1) of the Tax Code, and a non-resident is charged only on what Georgia sources to itself.

The United States starts somewhere else entirely. A US citizen or resident alien is taxed on worldwide income from all sources, and the rules for filing returns and paying estimated tax are generally the same whether you live in Ohio or in Tbilisi.

Green card holders are inside that rule too. A lawful permanent resident at any time during the calendar year is a resident alien, so a green card holder living in Georgia is taxed on the same basis as a citizen.

Becoming a Georgian tax resident decides what Georgia charges you. It decides nothing about what you owe the IRS.

When Georgia treats you as a tax resident

Georgia treats you as a tax resident for the whole of a tax year once you have actually been present in the country for 183 days or more across any continuous 12 calendar month period that ends in that year, under Article 34 of the Tax Code. Part of a day spent in Georgia counts as a whole one, and the status is set afresh for every tax period, so the days that made you a resident once are not counted again the following year.

Days spent outside Georgia for treatment, leisure, a business trip or study still count as presence in Georgia, while days spent in transit or in diplomatic or consular status do not count at all, which is why the arithmetic of the 183 days decides more borderline years than the calendar does.

Residency on that test comes from the facts alone. There is no application, no registration and no election, and a visa, a residence permit or a registered Tbilisi address neither creates it nor prevents it.

What Georgia taxes an American on

The general personal income tax rate for individuals is 20%. Which of your income Georgia calls its own matters more than the rate does.

Services actually rendered inside Georgia count as Georgian-source. So do services a Georgian resident supplies to a recipient in another state, unless a permanent establishment abroad delivers them. In deciding the source of income, the place where the money is received is not taken into account. So work you do from a flat in Tbilisi for clients in Chicago is Georgian-source income, not foreign income, and a US bank account changes nothing about that.

The exemption for a resident's foreign income is narrower than it sounds, because it reaches income whose source is outside Georgia, not income whose payer is.

The rent row and the small business row both turn on a condition the table cannot hold. The 5% on residential rent applies only to a landlord whose details are already on the Revenue Service register of people letting out residential space, and who claims no deductions. A company paying rent to a landlord absent from the register when the liability arises withholds 20% instead.

The 1% regime has no residency or citizenship condition, so an American individual entrepreneur can hold it. What closes it is the activity. Annex 4 of Government Resolution No 415 shuts 7 categories out of the regime: activities needing a licence or permit; activities needing significant investment; currency operations; the professions, meaning medical, architectural, advocacy or notary, audit and consulting work; gambling; the provision of personnel; and the production of excise goods. Consulting is named there in terms, which is why a US consultant cannot take the 1% status on that work whatever the income.

The US tax treaty question has two answers

The Georgian Ministry of Finance publishes its treaty network, and it runs to 58 treaties on the avoidance of double taxation in force. The United States is not on that list, and neither is the Soviet Union.

The IRS publishes the opposite. Its Georgia page states that Georgia is one of the former Soviet republics now covered by the treaty with the Commonwealth of Independent States, formerly the USSR, and the only document it offers is the 1973 income tax treaty. A separate suspension notice on that treaty is limited to Belarus and says nothing about Georgia.

That is a real conflict rather than an omission, because the same Georgian page lists the rest of the network with its in-force dates. Anyone who wants to take a Georgian tax position on the strength of the 1973 text needs that settled with the Georgian authorities first, in writing, before the return is filed.

Relief under the treaties Georgia does publish runs through Minister of Finance Order No 633, and it is built for residents of the countries on the Ministry of Finance list. The order carries 3 forms: Form No 1, the Georgian payer's report that it withheld at a treaty rate or withheld nothing; Form No 2, the non-resident's claim for a refund of tax already withheld; and Form No 3, the request for a certificate of tax paid in Georgia. With the United States off the list, none of that route is open on a US claim.

How the double bill is actually settled

While the treaty question stays open, the relief has to come off the US return, and there are 2 instruments for it.

The foreign earned income exclusion takes foreign earned income out of US taxable income up to USD 132,900 for tax years beginning in 2026, up from USD 130,000 for 2025, and it is claimed on Form 2555. To use it you need foreign earned income, a tax home in a foreign country, and one of 2 tests: bona fide residence in a foreign country for an uninterrupted period covering an entire tax year, or physical presence in a foreign country for 330 full days during any 12 consecutive months. A full day there means 24 consecutive hours from midnight to midnight spent in a foreign country, and time over international waters does not count.

The foreign tax credit is the other instrument, and a foreign tax qualifies for it on 4 tests: it must be imposed on you, you must have paid or accrued it, it must be your legal and actual foreign tax liability, and it must be an income tax or a tax in lieu of one. The IRS states that foreign taxes on wages, dividends, interest and royalties generally qualify. The 2 instruments do not stack on the same money, because no credit or deduction is allowed for foreign taxes paid on income excluded under the exclusion.

Self-employment tax sits outside both. It runs at 15.3%, made up of 12.4% for social security and 2.9% for Medicare, and it is owed once net earnings from self-employment reach USD 400. Claiming the exclusion does not reduce it, and the Social Security Administration's list of countries with social security agreements runs to 31 entries with Georgia absent, so there is no certificate of coverage to take you out of it.

Proving your Georgian residency

The Revenue Service issues the Georgian residency certificate under Order No 633. A resident applies for it electronically, stating name and full address in both Georgian and English plus a Georgian taxpayer identification number, and the certificate is returned electronically on the approved template.

The order sets one timing rule for requests made under it: the tax authority issues the document or notifies its decision in writing within 30 calendar days, and a deficient request gets a period to cure of no more than 30 calendar days. Where your home country uses its own residency form with a field for a foreign authority, the Revenue Service confirms your Georgian residency on that form with signature and official seal, against a notarised Georgian translation. A foreign residency certificate filed in Georgia needs no apostille and no legalisation.

Form 2555 does not ask for a foreign residency certificate at all. What it asks is whether you are required to pay income tax to the country you claim, which is the question a Georgian certificate answers.

Your Georgian filing year

Resident individuals whose income was never taxed at source file the annual return by 31 March of the year after the reporting year, paying the tax on the same date. Individual entrepreneurs are on the Revenue Service's list of annual filers, so are small and micro business holders with income taxed under general rules, so is anyone letting out property where the rent is not taxed at source, and so is any resident with Georgian-source income that nobody withheld on.

The year you arrive is the awkward one, because residency is decided on a 12-month window that can end inside it, so the first Georgian tax year after a move often takes in months when you had no Georgian obligations at all.

Where your income is split between US clients and Georgian work, the source rules decide how much of it Georgia reaches, and that is a position worth having set out in writing before the first return, in an opinion David Sisvadze signs.

Filing late costs 5% of the tax the return shows when it arrives up to 2 months after the deadline, and 10% once it is later than that, with nothing at all to pay where the return shows no tax. Late payment is charged interest at 0.05% a day on the tax still outstanding, and the day you pay counts as an overdue one. If you are not obliged to file, you may still file to claim a recalculation and a refund.

Georgian bank accounts and US reporting

An account at a Georgian bank is a foreign financial account to the United States, and it can trigger 2 separate reports. Neither depends on the account producing any income.

The FBAR is filed electronically through the BSA E-Filing System, and its extension to 15 October does not have to be requested. Georgia also reports on you directly: it has a Model 1 FATCA agreement with the United States, in force since 18 September 2015, under which Georgian financial institutions report US accounts to the Revenue Service, which passes the information to the IRS within 9 months of the end of each calendar year.

Frequently asked questions

Do US citizens living in Georgia still have to file US tax returns?

Yes. A US citizen or resident alien is taxed on worldwide income from all sources, and the rules for filing income, estate and gift tax returns and paying estimated tax are generally the same abroad as at home. The IRS also states that benefits such as the foreign earned income exclusion and the foreign tax credit can only be obtained by filing a US return, so filing is how relief is claimed rather than something relief replaces.

Is there a tax treaty between the United States and Georgia?

The two administrations do not publish the same answer. The Georgian Ministry of Finance lists 58 double taxation treaties in force and the United States appears nowhere on that list, while the IRS publishes that the 1973 treaty with the former USSR reaches Georgia, and offers that text as the Georgia treaty document. Treat it as an open question on the Georgian side and get the position confirmed before relying on it.

Does Georgia tax my US income if I live in Tbilisi?

It depends on where the work happens, not on who pays. A Georgian resident's non-Georgian-source income is exempt, but services you perform in Georgia are Georgian-source income even when the client and the bank account are American, and the place the money is received is not taken into account. Passive income genuinely sourced outside Georgia, such as a gain on assets located abroad, stays exempt.

How many days in Georgia make me a Georgian tax resident?

183 days or more of actual presence in any continuous 12 calendar month period ending in the tax year, which makes you resident for the whole of that year. Part days count as full days. Days abroad for treatment, leisure, a business trip or study still count as presence, and days in transit or in diplomatic status do not count at all.

Can an American get the 1% tax rate in Georgia?

Yes, if the activity qualifies. Small business status is granted to an entrepreneur natural person on tax registration, with no citizenship, residence permit or minimum presence condition anywhere in the test. The 1% applies to gross income from economic activity up to GEL 500,000 a year, and income above that limit is taxed at 3% from the start of the month the excess is recorded to the end of that calendar year. Consulting is one of the 7 categories of activity excluded outright.

Do I have to report my Georgian bank account to the US?

Yes, on FinCEN Form 114, once the aggregate value of all your foreign financial accounts goes above USD 10,000 at any point in the calendar year. The report is due 15 April with an automatic extension to 15 October, and whether the account produced taxable income makes no difference. Form 8938 is a separate obligation, and for someone living abroad and filing alone it starts at more than USD 200,000 on the last day of the tax year.

Do green card holders living in Georgia have the same obligations as citizens?

Yes. A lawful permanent resident at any time during the calendar year is a resident alien, taxed on worldwide income and filing on the same rules as a citizen. One difference does matter: the bona fide residence test is open to US citizens, and to resident aliens only where they are citizens or nationals of a country the United States has an income tax treaty with, so the physical presence test is the safer route for a green card holder.

When is my Georgian tax return due?

By 31 March of the year that follows the reporting year, with the tax settled on the same date. A return up to 2 months late costs 5% of the tax it shows, and 10% once it is later than that, with nothing to pay where the return shows no tax. Unpaid tax runs interest at 0.05% a day.