Can housing-related expenses that are not deductible as an itemized deduction (e.g. disallowed foreign mortgage interest and foreign real estate taxes) be used to increase the section 911 foreign housing exclusion or deduction?
TP had a mortgage balance in excess of $1million as of December 31, 2019 and this loan was taken in 2016.
Thank you in advance for your time and comment.
@itonewbie It seems that as foreign real estate taxes are deductible under IRC164(a)(1), it can not be included as part of the housing expenses under 911(c)(3)(A)(ii). Please let me have your thought on this. Thanks.
The statutory language is "of the kind deductible", not deduction allowed. That makes a difference in legal terms and is what guides judges in their rulings. There is no ambiguity or gray area in §911 for position taking, if that's what you are thinking.
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