Taxation and Regulatory Compliance

What Is the Form 2555 Physical Presence Test?

Learn the specific IRS rules for documenting time spent abroad. This guide explains how to accurately track your days to qualify for the Foreign Earned Income Exclusion.

U.S. citizens and resident aliens working abroad may be eligible for the Foreign Earned Income Exclusion (FEIE). This exclusion allows taxpayers to exempt a certain amount of their foreign-source earned income from U.S. income tax. For the 2025 tax year, the maximum exclusion is $130,000. To claim this benefit using Form 2555, a taxpayer must satisfy the tax home test and meet the requirements of either the Bona Fide Residence Test or the Physical Presence Test.

Understanding the Physical Presence Test Requirements

The Physical Presence Test is a mathematical calculation based on time spent in a foreign country. To meet this test, a U.S. citizen or resident alien must be physically present in one or more foreign countries for at least 330 full days during any period of 12 consecutive months. This test is not concerned with the nature of your residence or your intentions about returning to the United States; it is based solely on the number of days you are physically located within a foreign jurisdiction. The 330 qualifying days do not need to be consecutive.

The 12-month period is not restricted to a calendar year. It is any period of 12 consecutive months, and a taxpayer can select any 12-month period that allows them to meet the 330-day requirement. For example, a qualifying period could run from April 1, 2023, through March 31, 2024. This flexibility allows individuals to tailor the test to their specific travel schedules.

A full day is a continuous 24-hour period that begins at midnight. To count a day toward the 330-day requirement, you must be physically within a foreign country for that entire 24-hour span. Partial days do not count. If you arrive in a foreign country at 3:00 a.m., your first full qualifying day does not begin until the following day at midnight.

A foreign country includes any territory under the sovereignty of a government other than the United States, which encompasses that country’s airspace and territorial waters. Time spent on or over international waters does not count as time in a foreign country. This means days spent on a cruise ship in international waters or on a long-haul flight over an ocean are not qualifying days. U.S. territories such as Puerto Rico, Guam, and the U.S. Virgin Islands are not considered foreign countries for this test.

Calculating Your Qualifying Days

Meeting the 330-day requirement often depends on a strategic selection of your 12-month period. You are not required to begin the 12-month period on your first day in a foreign country, and you can choose the window that maximizes your qualifying days. For instance, if you worked abroad from March 1, 2023, to May 31, 2024, but took a 45-day trip to the U.S. in the winter, using the 2023 calendar year would likely cause you to fail. A more strategic approach would be to select a 12-month period like May 1, 2023, to April 30, 2024, which would exclude most of your U.S. travel.

A common point of error is the handling of travel days. Any day that you spend part of the day traveling to or from the United States will not count as a full day in a foreign country. For example, if you depart from Paris for New York at 10:00 p.m. on a Tuesday, that Tuesday does not count as a qualifying day. Similarly, if you arrive in London from Chicago at 9:00 a.m. on a Friday, your first full qualifying day in the United Kingdom would be Saturday.

This applies to flights and sea voyages. If a journey between two foreign countries involves travel over international waters and takes 24 hours or more, you will lose those days from your count. However, if you are in transit between two foreign locations and pass through the U.S. for less than 24 hours, you are not treated as being present in the U.S. during that transit. Instead, you are considered to be traveling over an area not within any foreign country.

You should maintain a detailed travel calendar that documents every arrival and departure date for any trip outside your foreign country of residence. Supporting documentation, such as passport stamps, airline tickets, and travel itineraries, provides proof to substantiate the dates entered on your tax forms. This documentation is the foundation for accurately calculating your 330 qualifying days.

Required Information for Form 2555

The Physical Presence Test is addressed in Part III of Form 2555. On line 16, you will enter the beginning and ending dates of the 12-consecutive-month period you have chosen to qualify under the test. This 12-month period must be a full 365 days (or 366 in a leap year).

The table in Part III requires you to list all your travel during this chosen 12-month period. For each trip, you must provide the name of the country you traveled to, the date you departed your foreign tax home, and the date you returned. You will then indicate the number of days you spent on that trip that do not count as days present in a foreign country.

Special Circumstances and Waivers

The 330-day requirement can be waived under specific circumstances. The IRS may waive the time requirements if you were forced to leave a foreign country because of war, civil unrest, or similar adverse conditions. This waiver is for individuals who would have otherwise met the Physical Presence Test had the adverse conditions not occurred.

To be eligible for the waiver, you must establish that your tax home was in the foreign country and that you were physically present there on or before the date the IRS designates as the start of the waiver period. You must also be able to show that you could have reasonably been expected to meet the 330-day requirement if not for the need to leave. Personal reasons like illness or a family vacation do not qualify you for this waiver.

To claim the waiver, you must write “Claiming Waiver” at the top of page 1 of Form 2555. You also need to attach a statement to your return explaining how you met the conditions for the waiver, including evidence that you reasonably expected to meet the time requirements. The IRS publishes an official list of countries and the specific time periods for which this waiver is available. This list is released annually in a Revenue Procedure.

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