Digital Nomad
Living and Working Abroad? Digital Nomads and Tax Home Rules After Sec. 911 Changes
New Revenue Procedure expands options for Foreign Earned Income Exclusion waivers for war-affected countries. Here’s what digital nomads and expats abroad need to know to protect their tax status.
By NomadicTax Research Team • 5-8 min read • November 18, 2025
## What’s Changed for Expats Under IRC Section 911
Under **Revenue Procedure 2025-17** (in the Internal Revenue Bulletin, Issue 13), the IRS has added **Ukraine, Iraq, Haiti, and Bangladesh** to the list of **waiver countries** for the time-residence requirements for foreign earned income exclusion. This affects tax year **2024**. The customary bona fide residence or physical presence tests are waived if you had to leave the foreign country due to war, civil unrest, or similar adverse conditions.([irs.gov](https://www.irs.gov/irb/2025-13_IRB?utm_source=openai))
In simple terms: if you were a digital nomad or expat living in one of those countries and forced to relocate because of conflict, you still may qualify for the exclusion even if you didn’t meet the usual time requirements.
---
## Foreign Earned Income Exclusion (FEIE): The Basics
- For **tax year 2024**, eligible individuals can exclude up to **$126,500** of foreign-earned income from their U.S. taxes.([irs.gov](https://www.irs.gov/irb/2025-13_IRB?utm_source=openai))
- To qualify, your tax home must be in a foreign country and you must either meet the **bona fide residence test** or the **physical presence test**—unless there’s a valid **waiver** for countries listed due to war or unrest.([irs.gov](https://www.irs.gov/irb/2025-13_IRB?utm_source=openai))
---
## Scenarios Where the Waiver Helps
**Example A**: Lina lived in Kyiv, Ukraine, from Jan-Sep 2024 but evacuated due to conflict in October. Although she didn’t meet the physical presence test (330 full days abroad), she can use the new waiver for Ukraine to still qualify for FEIE for 2024.
**Example B**: Ahmed was working in Iraq for 11 months in 2024 but had to leave mid-year for safety. Under new IRS rules, the typical minimum timeframe still may not be met, but with the waiver, he qualifies for the exclusion.
---
## Action Steps for Digital Nomads and Expats
- **Document departure** from country clearly—evacuation orders, press releases, official declarations.
- Confirm income was foreign-earned; maintain records of contracts, employer payments, and any applicable Foreign Tax Credits.
- File IRS Form 2555 and attach statement invoking section 911 waiver for a listed country.
- Monitor whether your country has been added or removed from waiver status—this tends to be updated annually.
---
## Why This Matters
- Without the waiver, many affected individuals would lose eligibility due to disruption beyond their control. This change ensures fairness for expats in conflict zones.
- Maintaining FEIE status can mean large tax savings; for those earning over six figures abroad, exclusion plus foreign tax credits often beats paying U.S. tax on same income.
---
## Considerations & Limitations
- Waiver exists only **for 2024** for the listed countries.
- You must have legitimate foreign earned income and proof your tax home remained abroad until forced departure.
- If you opt into foreign residence/physical presence test later years, different rules apply; future changes possible.
---
**Final word**: Digital nomads or expats displaced by war or unrest in certain countries can still secure valuable tax benefits thanks to new waivers under sec-911. Taking timely action and organizing documentation is essential.