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section 931 for the years in issue, then that compensation can be
excluded under section 911.
A. In General
Section 911(a) provides in part that a “qualified
individual” may elect to exclude from gross income his or her
“foreign earned income”. Section 911(b)(2) limits the amount of
the exclusion for foreign earned income to $70,000.
Section 911(b)(1)(A) defines the term “foreign earned
income” to mean, in general, “the amount received by such
individual from sources within a foreign country or countries
which constitute earned income attributable to services performed
by such individual” during the period set forth in section
911(d)(1). Section 911(b)(1)(B) excludes from foreign earned
income certain amounts not relevant to this case.
Section 911(d)(1) defines the term “qualified individual”
for purposes of section 911 to mean
an individual whose tax home is in a foreign country
and who is--
(A) a citizen of the United States and
establishes to the satisfaction of the Secretary
that he has been a bona fide resident of a foreign
country or countries for an uninterrupted period
which includes an entire taxable year, or
(B) a citizen or resident of the United
States and who, during any period of 12
consecutive months, is present in a foreign
country or countries during at least 330 full days
in such period.
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