ACA American Citizens Abroad

ACA works with the Swiss-American Chamber of Commerce, Democrats Abroad of Switzerland and Republicans Abroad of Switzerland on the housing cap tax issue.

Section 515 of TIRPA, enacted in May 2006, put a cap on the amount of rent that Americans residing overseas could exclude for U.S. tax purposes. The law, however, authorized the Treasury department to establish a list of cities of exception, which would be granted a high exclusion. On October 6, 2006, the Treasury department issued such a list in its Notice: 2006-87. While this list aims to attenuate the unjust double taxation linked to the limited general cap on the housing exclusion, it is far from complete. As the Treasury notice requested that comments on the list be addressed to the IRS, American Citizens Abroad coordinated with the Swiss-American Chamber of Commerce, Democrats Abroad of Switzerland and Republicans Abroad of Switzerland to jointly sign a letter addressed to the IRS pointing out the inadequacies of the list with regard to Switzerland. The organizations also emphasized that the need for a list of exceptions only highlights the aberration of the law enacted in May 2006.

For ACA's comments on this new notice, click here.

ACA strongly encourages its members in countries throughout the world to look carefully at the list of exception cities in Notice N2006-87 and send your comments to the IRS with copies to your Congressmen. Your Congressman and Senators will be sensitive to your complaints about administrative rulings which are detrimental to their constituents, and you should propose to your representatives to support your complaint to the IRS on this issue.

Quick reactions from abroad have already resulted in a supplementary list Notice 2007-25 adding additional cities to the list.

To email the IRS, the address is: This e-mail address is being protected from spam bots, you need JavaScript enabled to view it Be sure to include the notice number Notice 2006-87 in the subject line.
To write a letter, the address is: CC:PA:LPD:PR (Notice 2006-87), Room 5203, Internal Revenue Service, PO Box 7604, Washington, DC 20044, USA.