the Bona Fide Residency test has to do with your economic and social ties, whereas the Physical Presence Test has to do with the number of days you spend outside the U.S. To pass the Bona Fide Residence Test you must have more ties to a foreign country and be a resident of that country for an uninterrupted period that includes an entire tax year. Your client does not meet the the Bona Fide Residency test, but if he was out of the US for 330 full days he would meet the Physical Presence Test