Where’s your tax home?
December 3, 2020
Taxpayers who live and work outside the U.S. may be able to exclude foreign-earned income. Generally, to qualify, a taxpayer must have a tax home (his or her regular place of business) in another country and not have an abode in the U.S. An American pilot employed by a U.S. airline claimed this exclusion, stating that his international flying routes meant he had no regular place of business and that Thailand was his place of abode. But records showed his home base was California. He presented no evidence that he intended to be a Thailand resident, he paid no taxes there, and Thailand listed him as transient. So, the exclusion was denied. (TC Memo 2020-158)