Now I'm working with a CPA to get my 2011 taxes done and it turns out that I'm not eligible to contribute to an IRA because, if I take the FEIE (Foreign Earned Income Exemption), I don't have any income on which to pay tax,
Are you sure you need to use the FEIE? If your income is being taxed in China, and your income is not very high, you can simply use the Chinese taxes taken out as a tax credit against what your income would owe to the U.S. I was surprised this year to learn that China taxes my meager income at a higher rate than the U.S. would have. I was more than able to offset my U.S. tax liability with the taxes I paid to China. Was no need to go through all the FEIE paperwork and I still had Adjusted Gross Income. I'd be curious if this would allow you to invest in an IRA.
I've asked the CPA about this and never got a satisfactory (detailed) response other than her saying that I don't want to seem to be rescinding the FEIE. Why wouldn't I want to seem to do that? No idea.
Next year I'm hiring a different accountant or just doing it all myself.
I do want to continue pursuing this questions, but since we almost certainly won't be in China for more than two years, the plan for now is to set up a taxable investment account that I will roll over into an IRA and to buy CDs in China and take that cash back to the US. It'll avoid all the hassles (other than the problem of not having statements for the interest earned on the CDs…)