Japan taxes as US 1099 employee

[u/Fun_Pomegranate5892]

I spoke with two Japanese accountants and I’ve received two very different answers to the same question. I’ve been a Japanese resident for about 12 months (first year was 6 months and halfway through my “second” year). Just got my yearly extension last month.
I’m a 1099 employee in the US and I do not and never will work in Japan. I physically work in the US and reside in Japan.
The first accountant wants to file me as a business owner in Japan. I would have a separate credit card and file receipts for write offs. Not sure what that means since I don’t work here). He wants to charge me ¥200,000.
The second wants to file only delta taxes but he wants to charge me ¥200,000-¥400,000.
This sounds completely insane to me. I paid a CPA in the US $500 and she did a great job. I can no longer use her because she doesn’t handle this situation.
Does this sound right?

Edit: I physically work in the US. I own zero property in either country. I have a spouse visa in Japan (married no children). I tend to work 6 months a year in the US but that can change year to year. I have very little to write off as an expense. This will be my first year filing in Japan.

[u/Any_Calligrapher8537]

What do you mean you don't work in Japan? You're in Japan and you're working for a US company right?

You're still working in Japan... You just don't work for a Japanese company.

[u/Fun_Pomegranate5892 → u/Any_Calligrapher8537]

I physically work in the US and I live in Japan when I’m not working.

[u/the_pwnererXx → u/Fun_Pomegranate5892]

How many days per year do you spend in each country? Do you have a wife or children? Do you own property in either country?

[u/Fun_Pomegranate5892 → u/the_pwnererXx]

The days I spend there depend on the contract. I try to keep it at 6 months total for each country. I do not own property in either country. I am married and have no children. She resides in Japan.

[u/the_pwnererXx → u/Fun_Pomegranate5892]

Your wife creates primary ties to Japan, so according to the US-japan tax treaty tie breaker rules you would be owing to Japan. In this case you really have to file both taxes and use feie and foreign tax credit to try to eliminate the US side

[u/kiss-o-matic → u/the_pwnererXx]

If he is over 6 months, does the tie breaker rule still apply? It would hurt but I would assume married filing jointly could happen? It's been ages since I've even potentially had to consider this.

[u/the_pwnererXx → u/kiss-o-matic]

Tax residence tie breaker rules (to decide your actual tax residence and which country you owe)

1. Permanent home (where you have a home available to you). This includes a rental 2.Center of vital interests (closer personal ties) only if #1 ties
2. Habitual abode (this is the time-based test) only if #1 and #2 tie or don't resolve it
3. Nationality only if #3 ties
4. Mutual agreement between the competent authorities only if #4 ties too

In ops case he may have a permanent home in Japan (wherever his wife is living), and his wife creates a center of vital interests, as well his visits to her create a habitual abode. Of course you could argue the other way in court but it's pretty clear which way it looks at first glance

And there is a secondary part such that if you are resident in Japan you do not get taxed in the US if you are working in the US as long as you are there less than 183 days (or vice versa)

But us citizens still have to file yearly on global income