Browsing these forums for questions regarding Form 2555, for issues not mentioned in instructions it seems that there is no official answer. For example, during this year I got sick with the Coronavirus, and was sent to the US for treatment; however, I got sick pay from my company abroad during this time; therefore, for benefit of the doubt, I am planning to claim the entire time I was in the US as “on business”. However, there are other issues which are not so simple to decide. For those issues, am I supposed to use my best judgment? Can I get penalized if I do, as long as I follow all the instructions which are present? Here are a few examples:

  1. My stay abroad consists of about 40 trips between various countries. If I count the “full days” for each individual countries, then I will lose the transit days, and therefore be short of the 330 days. However, the instructions also say to omit trips between countries which lasted less than 24 hours. This means I can omit all the trips between countries. My plan is, in the “Country name” field of line 18, to put “Foreign countries”, without listing them individually. This would allow me to have enough full days to claim the 330 days.

  2. Even if I do the above, the 4 blanks provided on line 18 for listing the countries are not enough. I plan to add a sheet that lists the remaining trips. I know sometimes, filling out an extra copy of the entire form (2555 in this case) is required.

  3. The instructions say to “Exclude travel between foreign countries that did not involve travel ... in or over the US, for 24 hours or more”. If it’s transit between two entry points of Canada, which lasted less than 24 hours, does that mean that I can exclude it? Even though Canada is one country (i.e., travel is not between “countries”), the “in” after the ellipsis above seems to indicate that I should.

  4. For the “Other Foreign Earned Income” (line 23), the forms asks to list the Type and amount. However, there are no examples of the Types allowed. Therefore, I am planning to just make up a name for the Type field.

  5. The instructions say, “Up to two Forms 2555 can be included with a tax return, one per taxpayer.” So if I am single, I can only include one. However, there is only one place to list my employer — even though I worked for multiple during this time period, in different countries. Because I don’t know what to do better, I am listing the employer from whom I made the most money. Or should I list the employer for whom I worked the longest instead?

Is there a chance I can get penalized in case of an audit? I am still abroad, so going to a qualified IRS agent is not really an option.

1 Answer 1


You are interpreting Line 18 incorrectly. From the IRS website,

Change of Location

  • You can move about from one place to another in a foreign country or to another foreign country without losing full days; but if any part of your travel is not within a foreign country or countries and takes 24 hours or more, you will lose full days.

It seems that the "full days" in line 18(d) do not have to sum to 365. You are only to list your foreign country stays adjacent to your stays in the U.S. Also, list each stay in the U.S. Any gaps in your line 18 travels will be assumed to be travel and stays between foreign countries.

Though you are currently abroad, you can still hire a U.S. accountant or use tax software, if you wish to pay for a service to help you do your taxes correctly.

  • So for question 1, is my plan to put “Foreign countries” in the Country Name field the right approach? Or do I list the ~10 countries I stayed in on my first trip abroad in 2020?
    – Alex
    Commented Feb 19, 2021 at 15:59
  • If your 2020 stays were, starting Jan. 1st, Liechtenstein to Austria to USA to Ecuador to Colombia to Peru to Brazil to USA to Japan to Russia to Great Britain to Egypt to USA, then you would list the following stays: Austria, USA, Ecuador, Brazil, USA, Japan, Egypt, USA. You only list the stays in USA and adjacent stays to the USA, I believe. Commented Feb 19, 2021 at 20:56

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