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“foreign earned income”. Section 911(b)(2) limits the amount of
the exclusion for foreign earned income to $78,000 for 2001.
Section 911(b)(1)(A) defines “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 “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.
Section 911(d)(9) authorizes the Secretary to prescribe
“regulations as may be necessary or appropriate to carry out the
purposes of” section 911. Pursuant to that grant of authority,
the Secretary promulgated proposed regulations under section 911
in 1983, see 48 Fed. Reg. 33007 (July 20, 1983), and final
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Last modified: May 25, 2011