You&#x27;re right of course, but this is mostly by design. Rightly or wrongly, the US position is that you need to pay taxes to <i>someone</i>. I think the intent of the laws is at least arguably reasonable, but the execution isn&#x27;t great.<p>Assuming for the moment that the US isn&#x27;t going to stop taxing expats on foreign income, I do think the exclusion limit is too low by about half. Making it more like $200k would allow more highly paid &quot;normal workers&quot; to avoid the penalty, while still hitting the very wealthy purely looking at the tax dodge.<p>And the limitations on time spent in the US are absurdly low as well. I&#x27;m an academic, so if I attend a couple of conferences there, I actually have to count the days left when I book a holiday to spend with my family. I have almost as many paid vacation days in Iceland as I&#x27;m allowed to spend in the US without forfeiting my bona fide tax home status, which is ludicrous.