Along with a few others, Ciarán's amused by the US tax court's ruling that work carried out by American citizens in Antarctica doesn't qualify for "foreign earned income" exemption because Antarctica isn't a foreign country. Which it isn't. A country, I mean.
It's an entire continent subject to various competing claims, which remain unresolved. The 1959 Antarctic treaty which prohibits military activity and seeks to support scientific research and environmental protection purposely defers these claims.
And it's certainly not a "foreign country" with a government which might want to levy a tax on anyone working in its jurisdiction. I would think the reason for an exemption on foreign earned income is a recognition that income earned in a foreign country will be subject to the tax regime in that country and that a reciprocal rule would apply - any citizens of that foreign country working in the US would be subject to the US tax regime. Given that no Antarctican government exists and no Antarctican citizens are working in the US, all bets are off and the sad fact is that the American government asserts a right to a slice of the fruits of its citizens' labour and will only forego that right in favour of another government with what it considers to be a superior claim on that slice.
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