[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 10153 Introduced in House (IH)]
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119th CONGRESS
2d Session
H. R. 10153
To amend the Internal Revenue Code of 1986 to treat income earned by
United States merchant mariners as foreign earned income.
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IN THE HOUSE OF REPRESENTATIVES
August 27, 2026
Mr. Fitzpatrick (for himself, Mr. Suozzi, Ms. Malliotakis, and Mr.
Boyle of Pennsylvania) introduced the following bill; which was
referred to the Committee on Ways and Means
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A BILL
To amend the Internal Revenue Code of 1986 to treat income earned by
United States merchant mariners as foreign earned income.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``American Mariner Tax Fairness Act''.
SEC. 2. INCOME EARNED BY UNITED STATES MERCHANT MARINERS TREATED AS
FOREIGN EARNED INCOME.
(a) In General.--Section 911(d) of the Internal Revenue Code of
1986 is amended by redesignating paragraphs (5) through (9) as
paragraphs (6) through (10), respectively, and by inserting after
paragraph (4) the following new paragraph:
``(5) Special rules for united states merchant mariners.--
``(A) In general.--In the case of an individual who
is a United States merchant mariner--
``(i) notwithstanding paragraph (1), such
individual shall be treated as a qualified
individual with respect to the days described
in subparagraph (B)(i)(II) during which such
individual was actively employed on a
qualifying vessel while such vessel was used in
the United States foreign trade, and in
applying subsections (b)(2)(A), (c)(1)(B)(ii),
and (c)(2)(A)(ii) with respect to such
individual, only such days shall be taken into
account, and
``(ii) notwithstanding subsection
(b)(1)(A), any earned income received by such
individual which is attributable to such
employment with respect to such days shall
(subject to subsection (b)(1)(B)) be treated as
foreign earned income.
``(B) Definitions.--For purposes of this
paragraph--
``(i) United states merchant mariner.--The
term `United States merchant mariner' means any
individual who--
``(I) is a citizen or resident of
the United States, and
``(II) during any period of 12
consecutive months, is actively
employed on a qualifying vessel, while
such vessel is used in the United
States foreign trade, during at least
90 full days in such period.
``(ii) Qualifying vessel.--The term
`qualifying vessel' means a self-propelled (or
a combination self-propelled and non-self-
propelled) United States flag vessel of not
less than 6,000 deadweight tons used
exclusively in the United States foreign trade.
``(iii) United states foreign trade.--The
term `United States foreign trade' has the
meaning given such term by section 1355(a)(7)
(determined by inserting `(or a possession
thereof)' after `United States').
``(iv) United states flag vessel.--The term
`United States flag vessel' has the meaning
given such term by section 1355(a)(5).''.
(b) Conforming Amendments.--
(1) Section 911(f)(1) of such Code is amended by striking
``subsection (d)(6)'' and inserting ``subsection (d)(7)''.
(2) Section 1411(d)(2) of such Code is amended by striking
``section 911(d)(6)'' and inserting ``section 911(d)(7)''.
(c) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after the date of the enactment of
this Act.
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