Page:United States Statutes at Large Volume 122.djvu/1669

 12 2 STA T . 1 64 6 PUBLIC LA W 11 0– 24 5—J U NE 1 7, 200 8Suchanel ec tio n m a yb e r e v o k e dw ith the con s ent o f the Secretary .‘ ‘ ( f )COVER E DEXPAT R I ATE. —F or p urposes of this section , the term ‘covered e x patriate ’ has the meanin g given to such term by section 87 7 A (g)( 1 ).’’. ( 2 )C L ERI C ALA M E N DMENT.— T he table of chapters for sub - title B is amended by inserting after the item relating to chapter 1 4 the following new item

‘ CHAPTER15.GIF T S A NDB E QU ESTS F R OMEX PATRIATES. ’ ’. (c) D E F INITION OF TERMINATION OF U NITED STATE S CITI Z EN- S H IP.— (1) I N G ENERAL.—Section 77 0 1(a) is amended by adding at the end the following new paragraph: ‘‘( 5 0) TERMINATION OF U NITED STATES CITIZENSHIP.— ‘‘(A) IN GENERAL.—An individual shall not cease to be treated as a United States citi z en before the date on which the individual’s citizenship is treated as relin q uished under section 877A(g)(4). ‘‘(B) DUAL CITIZENS.—Under regulations prescribed by the Secretary, subparagraph (A) shall not apply to an indi- vidual who became at birth a citizen of the United States and a citizen of another country.’’. (2) CONFORMING AMENDMENTS.— (A) P aragraph (1) of section 877(e) is amended to read as follows: ‘‘(1) IN GENERAL.—Any long-term resident of the United States who ceases to be a lawful permanent resident of the United States (within the meaning of section 7701(b)( 6 )) shall be treated for purposes of this section and sections 2107, 2501, and 60 39G in the same manner as if such resident were a citizen of the United States who lost United States citizenship on the date of such cessation or commencement.’’. (B) Paragraph (6) of section 7701(b) is amended by adding at the end the following flush sentence: ‘‘An individual shall cease to be treated as a lawful permanent resident of the United States if such individual commences to be treated as a resident of a foreign country under the provisions of a tax treaty between the United States and the foreign country, does not waive the benefits of such treaty applicable to residents of the foreign country, and notifies the Secretary of the commencement of such treatment.’’. (C) Section 7701 is amended by striking subsection (n) and by redesignating subsections (o) and (p) as sub- sections (n) and (o), respectively. (d) TERMINATION OF SECTION 877.—Section 877 is amended by adding at the end the following new subsection: ‘‘(h) TERMINATION.—This section shall not apply to any indi- vidual whose expatriation date (as defined in section 877A(g)(3)) is on or after the date of the enactment of this subsection.’’. (e) INFORMATION R ETURNS.—Section 6039G is amended— (1) by inserting ‘‘or 877A’’ after ‘‘section 877(b)’’ in sub- section (a), and (2) by inserting ‘‘or 877A’’ after ‘‘section 877(a)’’ in sub- section (d). Regulations.26USC7 7 01.

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