Trouble is, everything isn't always as black and white as it first appears. Take, for example, the following scenario which is an absolutely true situation.
A very prominent multi-millionaire corporate attorney resides on 36th street in New York City in one of the few single family homes in Murray Hill. Actually, he resides there "almost full-time", with a short annual stay at his "legal" residence on the Isle of Man. That is where his business is "officially" located as well. Apparently he has to make the tiresome trek back to Europe every year to maintain his Isle of Man citizenship.
Before the tax laws were changed, income earned in a foreign country were subject to the tax of that country and not taxed in the U.S. This worked out very well if your company was located on the Isle of Man. Actually, it worked nicely for pretty much all the channel islands as most of them have no taxes. They are supported under various treaties with the E.U. or with their "protectorate" countries.
The New York attorney's income came from the Isle of Man company and because he was "officially" a resident of the Isle of Man, his "foreign earnings" were not subject to tax in the U.S. I'm sure there had to be a few adjustments to make everything work smoothly but being an attorney probably would help.
It is my understanding that the new laws still allow $80K of taxable income before any U.S. tax is imposed. With a good accountant and a good corporate attorney, I wonder how many millions you would have to earn to to end up with a taxable income of $80K.
As another thought, I wonder how many Americans living and working in another country actually have a taxable income above $80K.
Dave