Camille M. Castro (J.D. 2010, Syracuse) has published Note, Peculiar Polar Policy: The Internal Revenue Service's Treatment of Antarctica, 60 Syracuse L. Rev. 385 (2010).  Here is the Conclusion:

Currently, taxpayers in Antarctica are caught in a perpetual darkness in regards to their ability to claim the foreign earned income exclusion of § 911. Congress needs to amend § 911 to include Antarctica. Section 911's main purpose was to encourage U.S. participation in foreign workforces. Although the IRS and the courts refuse to classify Antarctica as a foreign country because of the Antarctic Treaty and the United States' desire to maintain neutrality in regards to Antarctica affairs, Congress needs to take action and amend § 911 so that Antarctic workers receive the same tax benefits as other workers abroad. Antarctica is a very important asset, especially with the increasing need for Antarctic resources. The Antarctic Treaty is reaching its fiftieth anniversary, and new developments such as UNCLOS should force Congress to reconsider Antarctica's classification. Until this time, taxpayers working in Antarctica will be forced to brave twenty-four hours of darkness in the arctic and permanent darkness in regards to their use of § 911.