Can Tax Payer be deemed as revoking §911 if they never elected it in the first place? I mean if client has always been taking the foreign tax credit from the inception and not foreign income exclusion. So they never elected the exclusion. IRS will not consider that Revoking? Would they? I have a client and they are just beginning to file their back year taxes since they moved abroad. I think it is beneficial to NOT EXCLUDE their foreign income and take the foreign credit.  Maybe in later years, we may consider electing the §911 for the TP. what do you think?