Rev. Proc. 2025-17, page 1382.
Internal Revenue Bulletin 2025-13 · 2026-10-03 edition · updated 2026-10-04 · United States
Generally, U.S. citizens or resident aliens living and working abroad are taxed on their worldwide income. However, if their tax home is in a foreign country and they meet either the bona fide residence test or the physical presence test, they can choose to exclude from their income a limited amount of their foreign earned income (up to $126,500 for 2024). Both the bona fide residence test and the physical presence test contain minimum time requirements. Revenue Procedure
Finding Lists begin on page ii.
2025-17 provides a waiver under section 911(d)(4) for the time requirements for individuals electing to exclude their foreign earned income who must leave a foreign country because of war, civil unrest, or similar adverse conditions in that country. Rev. Proc. 2025-17 adds Ukraine, Iraq, Haiti, and Bangladesh to the list of waiver countries for tax year 2024 for which the minimum time requirements are waived.
T.D. 10023, page 1259. These final regulations provide rules for the new section 45V tax credit for the production of qualified clean hydrogen that was added by the Inflation Reduction Act of 2022. The final regulations provide guidance on how to claim the section 45V credit, a production tax credit, the amount of which is dependent on the quantity and emissions intensity of the hydrogen produced. The final regulations also provide guidance on the election to treat qualified property that is part of a specified clean hydrogen production facility as energy property under section 48, which is part of the investment tax credit under section 46.
TAX CONVENTIONS¶
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