HR 10153

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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

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. <all>