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United States – IRS Guidance on Sec. 911 for Turkey

United States – IRS Guidance on Sec. 911 for Turkey

This report covers new countries for which the eligibility requirements of U.S. Internal Revenue Code section 911(d)(1) are waived.


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On April 6, 2018, the U.S. Internal Revenue Service (IRS) released an advance copy of Rev. Proc. 2018-231, which concerns individuals who failed to meet the eligibility requirements of either the bona fide residence test or the physical presence test under U.S. Internal Revenue Code (I.R.C.) section 911(d)(1) – and thus may not exclude foreign earned income and housing cost amounts from gross income – because war, civil unrest, or similar adverse conditions in a foreign country precluded the individuals from satisfying these requirements.2  The Rev. Proc. released on April 6:

  • does not list any countries for which the eligibility requirements of section 911(d)(1) are waived for tax year 2017; but
  • adds Turkey to the list of countries for which the eligibility requirements of section 911(d)(1) are waived for tax year 2016.


Individuals who would otherwise qualify for the foreign earned income and foreign housing cost exclusions, may lose the benefit of those exclusions if they leave a country prior to fulfilling the time requirements, which could affect the amount of tax they owe. 

A special exception to the time requirements to qualify for those exclusions is allowed for persons who are forced to leave a country – e.g., Turkey – designated by the IRS due to war, civil unrest, or other adverse conditions. 

Revenue Procedure 2018-23: Turkey in 2016

Rev. Proc. 2018-23 provides that for tax year 2017, the Treasury Department in consultation with the Department of State lists no countries where war, civil unrest, or similar adverse conditions precluded the normal conduct of business.

However, for tax year 2016, the Rev. Proc. states that an individual who left Turkey on or after October 29, 2016, will be treated as a “qualified individual” for purposes of section 911 with respect to the period during which that person was present in, or was a bona fide resident of, Turkey provided that the individual establishes a reasonable expectation of meeting the requirements of section 911(d) but for the adverse conditions.An individual who was first present, or established residency, in Turkey after October 29, 2016, is not eligible to qualify for the exception. 


1  Here is the advanced copy of Rev. Proc. 2018-23, (PDF 19.6 KB). Revenue Procedure 2018-23 will be published in Internal Revenue Bulletin 2018-17, dated April 23, 2018. 

2  For coverage of last year’s Rev. Proc. designating South Sudan, see GMS Flash Alert 2017-049, March 14, 2017. 

The above information is not intended to be "written advice concerning one or more Federal tax matters" subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230 as the content of this document is issued for general informational purposes only.


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