,i  #aaeth ,,congress  #b;d ,session    
,h4 ,r4 #gceh  ,,in ,,the ,,house ,,of  
,,representatives  ,december #bj1       
#bjah,mr4 ,holding introduced the       
following bill2 which was referred to   
the ,committee on ,ways and ,means  ,a  
,,bill  ,to amend the ,internal ,revenue
 ,code of #aihf to provide an           
alternative exclusion for nonresident   
citizens of the ,united ,states living  
abroad4  #a4 ,short title ,this ,act may
 be cited as the ,tax ,fairness for     
,americans ,abroad ,act of #bjah4  #b4  
,taxation of nonresident citizens  7a7  
,in general ,the ,internal ,revenue     
,code of #aihf is amended by inserting  
after section #iaa the following new    
section3  #iaa;,a4 ,alternative for     
nonresident citizens of the ,united     
,states living abroad  7a7  ,exclusion  
of foreign income from gross income  ,in
 the case of a qualified nonresident    
citizen1 there shall be excluded from   
the gross income of such individual1 and
 exempt from taxation under this        

subtitle1 for any taxable year--  7#a7  
the foreign earned income of such       
individual1 and  7#b7 the foreign       
unearned income of such individual4  7b7
 ,definitions ,for purposes of this     
section-- 7#a7 ,in general ,unless      
otherwise provided1 terms used in this  
section have the same meaning given such
 terms in section #iaa4  7#b7 ,qualified
 nonresident citizen ,the term qualified
 nonresident citizen means1 with respect
 to a taxable year1 a nonresident       
citizen who-- 7,a7 has not made the     
election described in section #iaa for  
such taxable year1 and  7,b7 makes an   
election under this paragraph4  7#c7    
,foreign earned income ,the term foreign
 earned income has1 with respect to a   
taxable year1 the meaning given such    
term in section #iaa7;b7--  7,a7 without
 regard to paragraph 7#b7 thereof1 and  
7,b7 if during the taxable year were    
substituted in paragraph 7#a77;,a7 for  
during the period described in          
subparagraph 7,a7 or 7,b7 of subsection 

7d77#a71 whichever is applicable4  7#d7 
,foreign unearned income  7,a7 ,in      
general ,the term foreign unearned      
income means income other than foreign  
earned income that is sourced outside   
the ,united ,states4  7,b7 ,exception   
,the term foreign unearned income shall 
only include income from the sale of    
personal property to the extent such    
income is attributable to periods during
 which the individual was a qualified   
nonresident citizen4  7c7 ,exclusion of 
gain during time as qualified           
nonresident citizen ,there shall be     
excluded from gross income of an        
individual any foreign unearned income  
from the sale of personal property to   
the extent such income is attributable  
to periods during which the individual  
was a qualified nonresident citizen4    
7d7  ,other rules  ,rules similar to the
 rules of paragraphs 7#d71 7#e71 7#f71  
7#g71 and 7#h7 of section #iaa7;d7 shall
 apply for purposes of this subsection4 
4  7b7 ,conforming amendment ,the table 

of sections for subpart ,b of part ,,iii
 of subchapter ,n of chapter #a of such 
,code is amended by inserting after the 
item related to section #iaa the        
following new item3  ,sec4 #iaa;,a4     
,alternative for nonresident citizens of
 the ,united ,states living abroad  4   
7c7 ,nonresident citizen defined  7#a7  
,in general ,section #ggja7;b7 of the   
,internal ,revenue ,code of #aihf is    
amended by adding the following new     
subparagraph3  7,c7 ,nonresident citizen
 ,the term nonresident citizen means1   
with respect to a taxable year1 an      
individual who-- 7i7 is a citizen of the
 ,united ,states1  7ii7 has a tax home  
in a foreign country1  7iii7 is in full 
compliance with ,united ,states income  
tax laws for the #c previous taxable    
years1 and  7iv7 either-- 7,i7          
establishes to the satisfaction of the  
,secretary that such individual has been
 a bona fide resident of a foreign      
country or countries for an             
uninterrupted period which includes an  

entire taxable year1 or  7,,ii7 is      
present in a foreign country or         
countries during at least #ccj full days
 during such taxable year4  7,d7        
,limitation on nonresident citizens ,the
 term nonresident citizen shall not     
include any ,federal employee4  4  7#b7 
,conforming amendment ,the heading of   
section #ggja7;b7 of such ,code is      
amended by striking and and inserting a 
comma and by inserting after nonresident
 alien the following3 1 and nonresident 
citizen4  7d7 ,effective date ,the      
amendments made by this section shall   
apply with respect to taxable years     
beginning after the date of the         
enactment of this ,act4