PlainBillCongress, translated.Legislation. Context. Public interest.Referred to the House Committee on Ways and Means.
Congressional Research Service
No official summary is available in the imported record yet.
People & committees
Rep. Fitzpatrick, Brian K. [R-PA-1] · R–PA
Legislative record
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Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Primary sources
Text links open the official source. We also preserved the text version used in the PlainBill explanation below.
No related bills are listed in this snapshot. This does not establish whether the proposal has appeared in earlier Congresses.
Source last updated: Sep 29, 2026. Consult Congress.gov for the current record.
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PlainBill explanation
Based on the full Introduced in House · 2026-08-27 text. This explanation has not received human editorial review. This overview describes the proposal’s major provisions; it does not establish what its real-world effects would be.
The proposed American Mariner Tax Fairness Act would let certain U.S. merchant mariners qualify for tax rules for income earned abroad. It would cover citizens and residents who meet a 90-full-day work requirement on qualifying U.S.-flag vessels engaged in U.S. foreign trade. Only pay attributable to qualifying workdays would receive this treatment, subject to section 911(b)(1)(B), whose terms are not supplied.
This Act may be cited as the American Mariner Tax Fairness Act.
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.
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.
Eligibility would require U.S. citizenship or residency and active employment on a qualifying vessel in U.S. foreign trade for at least 90 full days within a period of 12 consecutive months. The text does not require those workdays to be consecutive.
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.
A qualifying vessel would have to be a U.S.-flag vessel, be self-propelled or combine self-propelled and non-self-propelled components, measure at least 6,000 deadweight tons, and be used exclusively in U.S. foreign trade. The bill would use existing statutory definitions of U.S.-flag vessel and U.S. foreign trade, modifying the latter reference by inserting “(or a possession thereof)” after “United States.” The incorporated definitions are not supplied, so their full scope cannot be determined from this text alone.
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.
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).
The term United States flag vessel has the meaning given such term by section 1355(a)(5).
The bill would treat qualifying mariners as qualified individuals for qualifying employment days notwithstanding section 911(d)(1). Only those days would count when applying sections 911(b)(2)(A), (c)(1)(B)(ii), and (c)(2)(A)(ii). Pay attributable to those days would be classified as foreign earned income notwithstanding section 911(b)(1)(A), while remaining subject to section 911(b)(1)(B). The referenced provisions are not reproduced, so the supplied text does not establish their full operation or the resulting tax calculation.
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
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.
To insert the new mariner rule, the bill would renumber existing paragraphs 911(d)(5) through (9) as (6) through (10). It would also update references in sections 911(f)(1) and 1411(d)(2) from paragraph (6) to paragraph (7).
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
(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).
If enacted, the amendments would apply to tax years beginning after the enactment date.
The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
The supplied official-actions snapshot, updated September 29, 2026, records introduction in the House and referral to the House Committee on Ways and Means on August 27, 2026.
Source snapshot updated 2026-09-29T08:05:25Z. 2026-08-27: Referred to the House Committee on Ways and Means. 2026-08-27: Introduced in House
A closer look
Reviewed version: Introduced in House · 2026-08-27. These findings describe provisions and who may benefit; they are not judgments of waste, corruption, or motive.
This review covers the supplied bill text. “None identified” does not rule out provisions in later versions or accompanying reports and disclosures.
Provisions outside the bill’s main subject, or policy changes attached to appropriations.
None identified in the reviewed text
No unrelated provision or policy change attached to appropriations was identified in the complete supplied introduced text. This conclusion is limited to that version and does not establish absence in other versions or accompanying materials. The supplied sources do not establish any amendment attachment history.
Spending directed to particular recipients or places outside ordinary competitive or formula-based allocation.
None identified in the reviewed text
No congressionally directed spending for particular recipients or places was identified in the complete supplied introduced text. This conclusion is limited to that version and does not establish absence in other versions or accompanying materials. Formal earmark status cannot be established without the relevant supporting materials.
Narrow exceptions, exemptions, or preferential treatment that warrant a closer look.
Findings to examine
A materially narrow tax preference is identified in the cited finding. Classification does not establish its fiscal effect or merits.
The proposal's central policy is special foreign-earned-income tax treatment for qualifying U.S. merchant mariners, notwithstanding specified eligibility and income-classification provisions. The beneficiaries would be citizens or residents with at least 90 full days of qualifying employment in 12 consecutive months, restricted to specified U.S.-flag vessels of at least 6,000 deadweight tons used exclusively in U.S. foreign trade. This is an occupational tax preference; the supplied text does not establish the full effect of the referenced tax provisions or the amount of any tax benefit.
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
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.
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.
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.
Full text preserved for this analysis. Legislative record snapshot: Sep 29, 2026. How PlainBill uses AI