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The short answer. No. A reentry permit protects permanent resident status against a finding that the status was abandoned because of the length of an absence, and the statute confines its effect to showing a return from a temporary visit abroad, INA 223(e), 8 USC 1203(e). It does nothing about the residence requirements for naturalization. Keeping the status and keeping the naturalization clock running are separate problems with separate solutions.
The requirement the permit does not touch. Naturalization ordinarily requires five years of continuous residence as a permanent resident immediately preceding the application, physical presence in the United States for periods totaling at least half of that time, and three months of residence in the state or USCIS district where the application is filed, INA 316(a), 8 USC 1427(a). A three-year statutory residence period applies to certain applicants, including some married to United States citizens.
How an absence breaks continuity. An absence of one year or more during the required period breaks the continuity of residence, INA 316(b), 8 USC 1427(b). An absence of more than six months but less than one year also breaks it unless the applicant establishes otherwise, INA 316(b), and that regulation adds that the finding holds even where the applicant claimed no nonresident tax treatment, executed no abandonment of status, and remains a permanent resident under the immigration laws. Separately, a permanent resident who claims nonresident status for income tax purposes, or who fails to file returns on that basis, raises a rebuttable presumption of having relinquished permanent resident status.
Rebutting the six-month presumption. The regulation identifies four kinds of evidence, without limiting the field, that an absence did not disrupt continuity:
What a break actually costs. The clock restarts rather than pausing. An applicant whose continuity was broken by an absence of a year or more and who is subject to the five-year period may file four years and one day after returning to the United States to resume permanent residence; an applicant subject to the three-year period may file two years and one day after that return.
What does preserve continuous residence. The remedy is a separate application under INA 316(b). It is open to a permanent resident who has been physically present and residing in the United States for an uninterrupted period of at least one year after admission for permanent residence, and who is then employed by or under contract with the United States Government, by an American institution of research recognized as such, by an American firm or corporation engaged in whole or in part in developing the foreign trade and commerce of the United States or a majority-owned subsidiary of one, or by a public international organization of which the United States is a member, provided in that last case that the employment began only after admission for permanent residence, INA 316(b). This type of application must be filed before the applicant has been absent from the United States for a continuous period of one year. An approval extends to the spouse and dependent unmarried sons and daughters residing abroad as members of the household, INA 316(b).
Physical presence is a different requirement again. An approved N-470 protects continuity of residence but does not relieve the applicant of the physical presence requirement, except where the employment is by or under contract with the United States Government, INA 316(c). An applicant can therefore hold both a reentry permit and an approved N-470 and still be unable to naturalize on schedule for want of days in the United States.
Narrower routes for particular applicants. A permanent resident authorized to perform the ministerial or priestly functions of a religious denomination with a bona fide organization in the United States, or engaged solely as a missionary, brother, nun or sister by such a denomination or by an interdenominational mission organization, is covered by INA 317, 8 USC 1428. A permanent resident whose United States citizen spouse is regularly stationed abroad in qualifying employment may naturalize without a prior residence period or a specified period of physical presence, provided the applicant is in the United States at the time of naturalization and declares in good faith an intention to take up residence in the United States once the spouse’s assignment abroad ends, INA 319(b), 8 USC 1430(b).
Two documents, two purposes. A permanent resident planning a long absence who also intends to naturalize generally needs both a reentry permit, to protect the status, and, where the employment qualifies, an approved Form N-470, to protect the clock. Neither substitutes for the other, and the N-470 carries the tighter deadline, because it must be filed before a continuous year abroad has elapsed.
Reentry Permits introduces the subject and covers eligibility, filing and validity. What is the purpose of a reentry permit? explains what the document does and does not accomplish. Does a reentry permit guarantee readmission? addresses the limits of the document at the port of entry. Does a reentry permit overcome a ground of inadmissibility? takes up the admissibility side. Questions about a specific set of facts may be directed to Antao & Chuang through the firm’s contact page.