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Conversely, earned income abroad, and passive income from foreign securities, rental, or other items abroad, can be excluded from U.S. taxable income, or foreign taxes paid thereon, is required as credits against U.S. taxes due.

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Example: Mary, an American citizen, is single and lives in Bermuda. She earns a salary of $450,000. Part of Mary's income will be subject to U.S. transfer pricing taxes at the 39.6% tax rate.

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