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I have enhanced the article to address the tags. Also, I do not favor merger of the article into the general U.S. tax article. According to IRS statistics (not right at hand), there are over 300,000 people a year who file the form for this exclusion. Therefore, I have removed all the tags. Comments & edits welcome. Oldtaxguy (talk) 20:33, 2 December 2010 (UTC)[reply]
I recommend this article provide a detailed discussion of what constitutes establishing a foreign tax home. This is actually the more difficult element for many taxpayers and not discussing this in detail is misleading as they assume that meeting one of the two tests constitutes having a foreign tax home. Many of the tax court decisions sustaining the commissioner's disallowance of the exclusion rest on the failure of the taxpayer to establish that the tax home was permanent or at least intended to be so (being present on a fixed term contract or assignment, for example, has not demonstrated permanence in several cases). Congress was put off enough by the situation of Department of Defense contractors not qualifying for the exclusion that they were specifically qualified for it by statute, a qualification that does not extend beyond that class of taxpayers.
--Bemcfarland (talk) 23:39, 30 March 2019 (UTC)[reply]
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