What counts as a tax home for the Foreign Earned Income Exclusion if I have no permanent address?

A tax home for the Foreign Earned Income Exclusion is the general area of your principal place of business, regardless of where you maintain your family home. For digital nomads without a permanent address, the IRS looks at which foreign location has the strongest claim to being your business base.

The IRS two-part analysis:

1. Identify your principal place of business or employment. For digital nomads, this is the location where you most regularly work and maintain a base infrastructure.
2. Determine if that location is in a foreign country. If it is, you have a foreign tax home. If you have no clear principal place, the IRS defaults to your abode (based on family, economic, and personal ties).

What strengthens a foreign tax home claim:

• Duration in one foreign country per year
• Lease or housing contract
• Foreign bank and payment accounts
• Client contracts or business relationships in the country
• Residency visa or permit

What weakens a foreign tax home claim:

• Retaining a U.S. house used regularly
• Family remaining in the U.S. (spouse, children)
• Returning to the U.S. for long stretches each year
• A pattern of brief hops across many countries without any anchor

Abode concept matters:

• The IRS uses “abode” to catch cases where your business may be abroad, but your personal life remains in the U.S.
• If your abode is in the U.S., you do not have a foreign tax home even with 330 foreign days

Relevant case law: Sochurek v. Commissioner and Jones v. Commissioner both denied FEIE on tax-home grounds.

For FEIE strategy, see our Foreign Earned Income Exclusion guide or How Do I Establish a Tax Home in a Foreign Country?