eligiblity for roth ira contribution

Just wanted to confirm…I have a client that is a US citizen and works overseas and earns all of his income there. He does not file a US tax return and he makes about the equivalent of $36,000 US dollars.
Would he be able to make a Roth IRA contribution?



Why does he not file a US return?   If he should be filing and would be using the foreign earned income exclusion, he will not have any taxable comp with which to make an IRA contribution. 

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