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There is much confusion about what constitutes foreign earned income with respect to the residency location, the location where the work or service is performed, and supply of the salary or fee fee. Foreign residency or extended periods abroad among the tax payer is a qualification to avoid double taxation.

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Example: Mary, an American citizen, is single and lives in Bermuda. She earns transfer pricing an income of $450,000. Part of Mary's income will be subject to U.S. income tax at the 39.6% tax rate.

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