I have delt with many newer Nissans 06+. After just a couple years in the midwest salt they will seize solid. All the ones I have worked on have been in the lower control arms.
The problem is they seize into the bushing sleeve inside the control arm. The only success i have had getting them loose has taken hours of hammering on them with a air hammer, and keeping them soaking in penetrating oil. Heat is no help since they are sitting in a rubber bushing, and if you burn that up you will need new bushings or arms. Since few customers are willing to pay for many hours of labor to do this, they are usually left as is. Another way to deal with the problem is to get a saw blade between the frame and control arm and cut the bolts, then replace the whole control arm and bolts. This is also spendy.
If they really are in the upper arms they would be much harder to get at and that much more of a pain.