nto v. Director of Virgin Islands Bureau of Internal Revenue, noted, income tax residency requires "far less than domicile." (715 F.3d 455 at 466). See Treas. Reg §§ 20.0-1(b)(1) & 25.2501(b) for a definition of domicile for U.S. estate and gift tax purposes. Liberalizing the Presence Test by adopting a 3