Does foreign earned, excluded income count as gross income for the filing requirement?

Question

For a US citizen who qualifies for the foreign earned income exclusion, does income excluded in this way count towards gross income, as it relates to having to file an income tax return? I understand how the exclusion itself functions, but I am wondering if it's possible to utilize it to avoid needing to file a return.

According to the IRS, for tax year 2014:

If you are a U.S. citizen or a resident alien of the United States and you live abroad, you are taxed on your worldwide income. However, you may qualify to exclude from income up to $99,200 of your foreign earnings.
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The foreign earned income exclusion is voluntary. You can choose the exclusion by completing the appropriate parts of Form 2555.
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If you are claiming the foreign earned income exclusion only, you can use Form 2555. In some circumstances, you can use Form 2555-EZ to claim the foreign earned income exclusion. You must file one of these forms each year you are claiming the exclusion.

But also (emphasis added):

The amount of foreign earned income (and foreign housing costs) excluded from an individual's gross income will be used for purposes of determining the rate of income tax and alternative minimum tax (AMT) that applies to his or her nonexcluded income.

And USC 26, section 911 says^1,2:

(a) Exclusion from gross income
At the election of a qualified individual (made separately with respect to paragraphs (1) and (2)), there shall be excluded from the gross income of such individual, and exempt from taxation under this subtitle, for any taxable year—
(1) the foreign earned income of such individual, and
(2) the housing cost amount of such individual.

For 2014, if your gross income is less than $10,000, you do not have to file a return. If all income qualifies for the FEIE, and is more than 10K but less than 99K, is filing required (because the exclusion is optional, so one must file form 2555 to take it), or not (because gross income is less than 10K)? Note that the exclusion specifically alters gross, and not adjusted gross, income.

Here's a (hopefully) simple example. Say for 2014 the following applies:

1. Qualify for the foreign earned income exclusion for the entire year
2. Earned $50,000 working outside the US, and it all qualifies for the exclusion
3. Earned no income inside the US
4. Paid no US tax and thus cannot receive a refund
5. All other credits, deductions, etc. do not apply (to keep things simple)
6. No other parties involved (single, no dependents, cannot be claimed as a dependent, etc.)
7. Not otherwise required or wishing to file

From 1-3, gross income is calculated as $0, because all $50K of foreign earnings is excluded. Since gross income is less than $10K, is it still required to file a return? If not, are there any reasons to do so anyway?

Answer 1

Yes, the excluded income counts towards the filing requirement. From IRS Publication 54, Chapter 1, Section "Filing Requirements":

For purposes of determining whether you must file a return, gross income includes any income that you can exclude as foreign earned income or as a foreign housing amount.

So in your example, yes, you would be required to file.