Late in the year, the Tax Court issued Hudson v. IRS, T.C. Memo 2017-221 (November 8, 2017), in which it affirmed the IRS’s denial of the Foreign Earned Income Exclusion for failure to establish a bona fide foreign residence and failure to meet the physical presence test. Unfortunately, it was not necessary to analyze, and the court did not analyze, the tax home element of the Foreign Earned Income Exclusion law (IRC Section 911). Recall, that the Foreign Earned In [...]
