You pay taxes to both. If there are treaties, then best case is you end up with a tax burden that is equal to whichever is higher. Treaties will usually let yo

You pay taxes to both. If there are treaties, then best case is you end up with a tax burden that is equal to whichever is higher. Treaties will usually let you claim credits for foreign taxes paid. Navigating how to apply for the treaty benefits will be a huge PITA though... In the worst case you may end up being double taxed on some aspects of your income. Sometimes treaties don't credit you for all types of taxes paid and tax-deferred/advantaged investment accounts (retirement or otherwise) may also not be fully recognized across jurisdictions, making them not actually tax-deferred/advantaged. Would be a large YMMV situation, though the silver lining is that figuring out how to navigate this would largely be a one-time cost.