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119-hr-10153119th CongressWALLET

American Mariner Tax Fairness Act

Sponsored By: Representative Fitzpatrick, Brian K. [R-PA-1]

Introduced

Summary

Expands the foreign earned income exclusion for U.S. merchant mariners. This bill would let U.S. merchant mariners treat pay earned on qualifying days aboard certain U.S.-flag foreign trade vessels as foreign earned income for the foreign earned income exclusion.

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  • Workers: U.S. merchant mariners who are U.S. citizens or residents could exclude pay earned on qualifying days from U.S. taxable income, which may lower their U.S. tax on that pay. The rule applies only for mariners who work at least 90 full days in any 12-month period.
  • Eligibility rules: To qualify the vessel must be a U.S.-flag ship of at least 6,000 deadweight tons used exclusively in U.S. foreign trade. Only days actively employed on those voyages count toward the exclusion.
  • Tax code alignment: The bill adds a new special rule to section 911(d), adjusts internal cross references in sections 911(f)(1) and 1411(d)(2), and applies to taxable years beginning after enactment.

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Bill Overview

Analyzed Economic Effects

1 provisions identified: 1 benefits, 0 costs, 0 mixed.

Lower taxes for U.S. merchant mariners

If enacted, this bill would let some U.S. merchant mariners treat certain wages as foreign earned income. You would need to be a U.S. citizen or resident. Within any 12-consecutive-month period, you would need at least 90 full days actively employed on a qualifying vessel. A qualifying vessel would be U.S.-flag, at least 6,000 deadweight tons, and used only in U.S. foreign trade. Only days you worked on that vessel while it was used in U.S. foreign trade would count for the foreign earned income test. Pay for those days would be treated as foreign earned income, subject to the foreign earned income exclusion dollar limit. The changes would apply for taxable years beginning after the date of enactment.

Sponsors & CoSponsors

Sponsor

Fitzpatrick, Brian K. [R-PA-1]

PA • R

Cosponsors

  • Rep. Panetta, Jimmy [D-CA-19]

    CA • D

    Sponsored 9/28/2026

  • Rep. Suozzi, Thomas R. [D-NY-3]

    NY • D

    Sponsored 8/27/2026

  • Rep. Malliotakis, Nicole [R-NY-11]

    NY • R

    Sponsored 8/27/2026

  • Rep. Boyle, Brendan F. [D-PA-2]

    PA • D

    Sponsored 8/27/2026

  • Rep. Tenney, Claudia [R-NY-24]

    NY • R

    Sponsored 9/15/2026

  • Rep. Moran, Nathaniel [R-TX-1]

    TX • R

    Sponsored 9/21/2026

Roll Call Votes

No roll call votes available for this bill.

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