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While we're discussing the foreign earned income exclusion (FEIE) and IRA contributions, I have a question in that regard.

DW and I file MFJ. She contributes to her employer provided 401(k). I pay into a "foreign retirement plan" (FRP) that has some employer match. However, my FRP is not "qualified" in two respects: First, Form 2555 indicates that I include my employer-match contributions as FEI. Second, I will not be able to make a rollover contribution from my FRP to my IRA when I repatriate (the repatriating USians at my job who have attempted this have failed).

So, to my mind, it seems that the IRS does not consider me "covered by a retirement plan at work" (quote from Pub. 590). Thus, In terms of qualifying for an IRA deduction, our eligibility phase-out should begin at $173K, not $92K. Is this correct?
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