John A. Bogdanski (Lewis & Clark) has posted Wanted: ‘Check-the-Box’ Residency for Foreign Students, 131 Tax Notes 852 (May 23, 2011), on SSRN. Here is the abstract:
In the U.S. tax system, foreign students are treated as nonresidents, which perhaps unintentionally places many of them at a disadvantage. This article presents a modest proposal for a new regime under which nonresident alien students may elect to be treated as residents of the United States for federal income tax purposes.



