Sorry, but this is creating a problemm where none exists. It says
for a period not exceeding 2 years from the date of his arrival in the other State.
. It does not say
calendar years, it does not say
from January 1 of the year of his arrival, it does not say or imply any other reading than the obvious one.
Random examples from the treaty with France:
The provisions concerning other taxes generally will take effect for taxable years or taxable events occurring on or after January 1 of the year following the entry into force.
the assets situated outside of France that such a person owns on the first of January of each of the five years following the calendar year in which he becomes a resident of France shall be excluded from the base of assessment of the above- mentioned wealth tax relating to each of those five years.
If such an individual loses the status of resident of France for a duration of at least three years and again becomes a resident of France, the assets situated outside of France that such a person owns on the first of January of each of the five years following the calender year in which he again becomes a resident of France shall be excluded from the base of assessment of the tax relating to each of those five years.
The case must be presented within three years of the notification of the action resulting in taxation not in accordance with the provisions of this Convention.
Random examples from the technical explanation:
may terminate the Convention at any time after five years from the date on which it enters into force, provided that notice has been given through diplomatic channels at least six months before the end of a calendar year.
whose loss of citizenship had as one of its principal purposes the avoidance of U.S. income tax, for ten years following the loss of citizenship.
Such a former citizen is taxable in accordance with the provisions of section 877 of the Code for ten years following the loss of citizenship.
. (877 says
within the 10-year period immediately preceding the close of the taxable year,
but the combined period of benefits may not exceed five years.
a case must be presented to the competent authorities no later than three years from the notification of the assessment which gives rise to the taxation
Either for the taxable year concerned, or as an average for the preceding four years,