H.R. 10153

[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.
_______________________________________________________________________
                    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
_______________________________________________________________________
                                 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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