I 

118TH CONGRESS 

2D SESSION H. R. 10468 

To amend the Internal Revenue Code of 1986 to establish an elective residency-based income tax for nonresident citizens of the United States, 

and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

DECEMBER 18, 2024 

Mr. LAHOOD introduced the following bill; which was referred to the 

Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to establish 

an elective residency-based income tax for nonresident 

citizens of the United States, and for other purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Residence-Based Tax5 ation for Americans Abroad Act’’. 


ssavage on LAPJG3WLY3PROD with BILLS
2 

•HR 10468 IH

1 SEC. 2. ESTABLISHMENT OF ELECTIVE RESIDENCY-BASED 

2 INCOME TAX FOR NONRESIDENT CITIZENS 

3 OF THE UNITED STATES. 

4 (a) IN GENERAL.—Part II of subchapter N of chap5 ter 1 of the Internal Revenue Code of 1986 is amended 

6 by adding at the end the following new subpart: 

7 ‘‘Subpart E—Residency-based Income Tax for 

8 Nonresident Citizens of the United States 

‘‘Sec. 899. Election by nonresident citizens of the United States to be subject 

to residency-based income tax rules. 

‘‘Sec. 899A. Imposition of tax on deferred income of certain electing individuals. 

‘‘Sec. 899B. Certificates of nonresidency. 

‘‘Sec. 899C. Regulations. 

9 ‘‘SEC. 899. ELECTION BY NONRESIDENT CITIZENS OF THE 

10 UNITED STATES TO BE SUBJECT TO RESI11 DENCY-BASED INCOME TAX RULES. 

12 ‘‘(a) IN GENERAL.—In the case of any electing indi13 vidual: 

14 ‘‘(1) RESIDENCY-BASED INCOME TAX.—The 

15 rules of subsection (b) shall apply for the taxable 

16 year for which the election under this section is 

17 made and all subsequent taxable years until such 

18 election is terminated under subsection (d). 

19 ‘‘(2) APPLICATION OF TAX ON DEFERRED IN20 COME.—The rules of section 899A shall apply as of 

21 the day before the election date (as defined in sec22 tion 899A). A termination of any election under this 


ssavage on LAPJG3WLY3PROD with BILLS
3 

•HR 10468 IH

1 section shall have no effect on the application of sec2 tion 899A. 

3 ‘‘(b) APPLICATION OF RESIDENCY-BASED INCOME

4 TAX.—In the case of any electing individual, the rules of 

5 this subsection are as follows: 

6 ‘‘(1) IN GENERAL.—Section 7701(b)(1) shall be 

7 applied— 

8 ‘‘(A) by treating any electing individual as 

9 an alien individual, 

10 ‘‘(B) by substituting ‘not’ for ‘neither a 

11 citizen of the United States nor’ in subpara12 graph (B), and 

13 ‘‘(C) by treating the United States as in14 cluding the possessions of the United States. 

15 ‘‘(2) MODIFICATION OF SUBSTANTIAL PRES16 ENCE TEST.—Section 7701(b)(3) shall applied with17 out regard to subparagraphs (B) and (C). 

18 ‘‘(3) REQUIREMENT OF TAX RESIDENCY.—Not19 withstanding section 7701(b), an electing individual 

20 shall not fail to be treated as a resident of the 

21 United States unless such individual is a tax resi22 dent of a foreign country. 

23 ‘‘(4) TREATMENT AS UNITED STATES PERSONS

24 BASED ON RESIDENCY.—Section 7701(a)(30)(A) 


ssavage on LAPJG3WLY3PROD with BILLS
4 

•HR 10468 IH

1 shall be applied without regard to the phrase ‘a cit2 izen or’. 

3 ‘‘(5) COORDINATION WITH FATCA WITH4 HOLDING.—For purposes of section 1472, an elect5 ing individual with a certificate of nonresidency 

6 issued under section 899B shall be treated as having 

7 established status as an individual who is not a spec8 ified United States person. 

9 ‘‘(6) EXEMPTION FROM CERTAIN REPORTING

10 AND RECORDS REQUIREMENTS WITH RESPECT TO

11 FOREIGN ASSETS AND TRANSACTIONS.—Sections 

12 6038D and 6046, and section 5314 of title 31, 

13 United States Code, shall not apply. 

14 ‘‘(7) COORDINATION WITH RULES ON EXPA15 TRIATION.—Section 7701(a)(50) shall not be treated 

16 as applying with respect to the application of this 

17 subpart. 

18 ‘‘(8) WAIVER OF TREATY SAVING CLAUSE.— 

19 The United States waives the application of each 

20 saving clause in any United States income tax treaty 

21 with respect to electing individuals. For purposes of 

22 the preceding sentence, the term ‘saving clause’ 

23 means any provision which would (but for this para24 graph) prevent the electing individual from benefitVerDate Sep 11 2014 00:09 Jan 24, 2025 Jkt 059200 PO 00000 Frm 00004 Fmt 6652 Sfmt 6201 E:\BILLS\H10468.IH H10468

ssavage on LAPJG3WLY3PROD with BILLS
5 

•HR 10468 IH

1 ting from a provision of the treaty eliminating dou2 ble taxation. 

3 ‘‘(c) ELECTING INDIVIDUAL.—For purposes of this 

4 subpart— 

5 ‘‘(1) IN GENERAL.—The term ‘electing indi6 vidual’ means any citizen of the United States who 

7 has in effect an election (made at such time and in 

8 such manner as the Secretary may provide) to have 

9 the provisions this subpart apply. 

10 ‘‘(2) CITIZENS BORN ABROAD.—In the case of 

11 any citizen of the United States who is born outside 

12 the United States, such individual shall be treated as 

13 a electing individual until such time as such indi14 vidual becomes a resident of the United States 

15 under clause (ii) or (iii) of section 7701(b)(1)(A). 

16 ‘‘(3) EXCEPTION FOR FEDERAL EMPLOYEES.— 

17 Notwithstanding any other provision of this subpart, 

18 an individual shall not be treated as an electing indi19 vidual for any taxable year if such individual is em20 ployed by the Federal Government at any time dur21 ing such taxable year. 

22 ‘‘(d) RULES RELATED TO ELECTION.— 

23 ‘‘(1) MANNER OF ELECTION.—An election 

24 under this section shall be made at such time and 

25 in such manner as the Secretary may provide and, 


ssavage on LAPJG3WLY3PROD with BILLS
6 

•HR 10468 IH

1 once made, is irrevocable (but may be terminated as 

2 provided in this section). 

3 ‘‘(2) REQUIREMENTS OF ELECTION.—An elec4 tion under this section shall not be effective unless— 

5 ‘‘(A) the tax imposed under section 899A 

6 (if any) is paid (or deferred under section 

7 899A(b)) at such time as the Secretary may 

8 provide, and 

9 ‘‘(B) the electing individual certifies under 

10 penalty of perjury that the electing individual 

11 has met the requirements of this title for the 5 

12 preceding taxable years and submits such evi13 dence of such compliance as the Secretary may 

14 require. 

15 ‘‘(3) TERMINATION OF ELECTION.—An election 

16 under this section— 

17 ‘‘(A) shall be terminated as of the close of 

18 the taxable year preceding any taxable year 

19 (with respect to which the election would other20 wise apply) for which the electing individual is 

21 a resident of the United States under clause (ii) 

22 or (iii) of section 7701(b)(1)(B), and 

23 ‘‘(B) may be terminated by the electing in24 dividual at such time and in such manner as 

25 the Secretary may provide. 


ssavage on LAPJG3WLY3PROD with BILLS
7 

•HR 10468 IH

1 ‘‘(e) SPECIAL RULE FOR SHORT-TERM NONRESI2 DENCY.—If an election under this section by an electing 

3 individual is terminated before the beginning of the fourth 

4 taxable year to which such election would otherwise apply, 

5 subsection (b) shall not apply to any taxable year to which 

6 such election would have otherwise applied. 

7 ‘‘SEC. 899A. IMPOSITION OF TAX ON DEFERRED INCOME OF 

8 CERTAIN ELECTING INDIVIDUALS. 

9 ‘‘(a) GENERAL RULES.—For purposes of this sub10 title— 

11 ‘‘(1) DEEMED SALE.—All property of a speci12 fied electing individual shall be treated as sold on 

13 the day before the election date for its fair market 

14 value. 

15 ‘‘(2) RECOGNITION OF GAIN OR LOSS.—In the 

16 case of any sale under paragraph (1)— 

17 ‘‘(A) notwithstanding any other provision 

18 of this title, any gain arising from such sale 

19 shall be taken into account for the taxable year 

20 of the sale, and 

21 ‘‘(B) any loss arising from such sale shall 

22 be taken into account for the taxable year of 

23 the sale to the extent otherwise provided by this 

24 title, except that section 1091 shall not apply to 

25 any such loss. 


ssavage on LAPJG3WLY3PROD with BILLS
8 

•HR 10468 IH

1 Proper adjustment shall be made in the amount of 

2 any gain or loss subsequently realized for gain or 

3 loss taken into account under the preceding sen4 tence. 

5 ‘‘(b) SPECIFIED ELECTING INDIVIDUAL.—For pur6 poses of this section— 

7 ‘‘(1) IN GENERAL.—The term ‘specified electing 

8 individual’ means any electing individual if the net 

9 worth of the individual as of the election date ex10 ceeds the basic exclusion amount in effect under sec11 tion 2010(c)(3) as of such date. 

12 ‘‘(2) NET WORTH.—The term ‘net worth’ 

13 means, with respect to any electing individual, the 

14 excess (if any) of— 

15 ‘‘(A) the fair market value of all assets of 

16 such individual, over 

17 ‘‘(B) the indebtedness of such individual. 

18 ‘‘(c) ELECTION DATE.—For purposes of this section, 

19 the term ‘election date’ means the first day of the first 

20 taxable year to which the election under section 899 ap21 plies. 

22 ‘‘(d) EXCEPTIONS.— 

23 ‘‘(1) IN GENERAL.—Subsection (a) shall not 

24 apply to any interest in the following property of the 

25 specified electing individual: 


ssavage on LAPJG3WLY3PROD with BILLS
9 

•HR 10468 IH

1 ‘‘(A) Any deferred compensation item. 

2 ‘‘(B) Any qualified retirement plan (as de3 fined in section 4974(c)). 

4 ‘‘(C) Any specified tax deferred account. 

5 ‘‘(D) Any interest in a nongrantor trust. 

6 ‘‘(E) Any real property located in the 

7 United States. 

8 ‘‘(F) Any real property located outside the 

9 United States if, during the 5-year period end10 ing on the election date, such property has been 

11 owned and used by the specified electing indi12 vidual as such individual’s principal residence 

13 for periods aggregating 2 years or more. 

14 ‘‘(2) DEFERRED COMPENSATION ITEM.—For 

15 purposes of this subsection, the term ‘deferred com16 pensation item’ means— 

17 ‘‘(A) any interest in a plan or arrangement 

18 described in section 219(g)(5), 

19 ‘‘(B) any interest in a foreign pension plan 

20 or similar retirement arrangement or program, 

21 ‘‘(C) any item of deferred compensation, 

22 and 

23 ‘‘(D) any property, or right to property, 

24 which the individual is entitled to receive in 

25 connection with the performance of services to 


ssavage on LAPJG3WLY3PROD with BILLS
10 

•HR 10468 IH

1 the extent not previously taken into account 

2 under section 83 or in accordance with section 

3 83. 

4 ‘‘(3) SPECIFIED TAX DEFERRED ACCOUNT.— 

5 For purposes of this subsection, the term ‘specified 

6 tax deferred account’ means a qualified tuition pro7 gram (as defined in section 529), a qualified ABLE 

8 program (as defined in section 529A), a Coverdell 

9 education savings account (as defined in section 

10 530), a health savings account (as defined in section 

11 223), and an Archer MSA (as defined in section 

12 220). 

13 ‘‘(4) NONGRANTOR TRUST.—For purposes of 

14 this subsection, the term ‘nongrantor trust’ means 

15 the portion of any trust that the specified electing 

16 individual is not considered the owner of under sub17 part E of part I of subchapter J. The determination 

18 under the preceding sentence shall be made imme19 diately before the election date. 

20 ‘‘(e) ELECTION TO DEFER TAX.— 

21 ‘‘(1) IN GENERAL.—If the specified electing in22 dividual elects the application of this subsection with 

23 respect to any non-readily tradable property treated 

24 as sold by reason of subsection (a), the time for pay25 ment of the additional tax attributable to such propVerDate Sep 11 2014 00:09 Jan 24, 2025 Jkt 059200 PO 00000 Frm 00010 Fmt 6652 Sfmt 6201 E:\BILLS\H10468.IH H10468

ssavage on LAPJG3WLY3PROD with BILLS
11 

•HR 10468 IH

1 erty shall be extended until the due date of the re2 turn for the taxable year in which such property is 

3 disposed of (or, in the case of property disposed of 

4 in a transaction in which gain is not recognized in 

5 whole or in part, until such other date as the Sec6 retary may prescribe). 

7 ‘‘(2) DETERMINATION OF TAX WITH RESPECT

8 TO PROPERTY.—For purposes of paragraph (1), the 

9 additional tax attributable to any property is an 

10 amount which bears the same ratio to the additional 

11 tax imposed by this chapter for the taxable year 

12 solely by reason of subsection (a) as the gain taken 

13 into account under subsection (a) with respect to 

14 such property bears to the total gain taken into ac15 count under subsection (a) with respect to all prop16 erty to which subsection (a) applies. 

17 ‘‘(3) TERMINATION OF EXTENSION.—The due 

18 date for payment of tax may not be extended under 

19 this subsection later than the due date for the re20 turn of tax imposed by this chapter for the taxable 

21 year which includes the date of death of the speci22 fied electing individual (or, if earlier, the time that 

23 the security provided with respect to the property 

24 fails to meet the requirements of paragraph (4), unVerDate Sep 11 2014 00:09 Jan 24, 2025 Jkt 059200 PO 00000 Frm 00011 Fmt 6652 Sfmt 6201 E:\BILLS\H10468.IH H10468

ssavage on LAPJG3WLY3PROD with BILLS
12 

•HR 10468 IH

1 less the electing individual corrects such failure with2 in the time specified by the Secretary). 

3 ‘‘(4) NON-READILY TRADABLE PROPERTY.—For 

4 purposes of this subsection, the term ‘non-readily 

5 tradable property’ means any property other than 

6 property which is readily tradable on an established 

7 securities market. 

8 ‘‘(5) SECURITY.— 

9 ‘‘(A) IN GENERAL.—No election may be 

10 made under paragraph (1) with respect to any 

11 property unless adequate security is provided 

12 with respect to such property. 

13 ‘‘(B) ADEQUATE SECURITY.—For purposes 

14 of subparagraph (A), security with respect to 

15 any property shall be treated as adequate secu16 rity if— 

17 ‘‘(i) it is a bond which is furnished to, 

18 and accepted by, the Secretary, which is 

19 conditioned on the payment of tax (and in20 terest thereon), and which meets the re21 quirements of section 6325, or 

22 ‘‘(ii) it is another form of security for 

23 such payment (including letters of credit) 

24 that meets such requirements as the Sec25 retary may prescribe. 


ssavage on LAPJG3WLY3PROD with BILLS
13 

•HR 10468 IH

1 ‘‘(6) WAIVER OF CERTAIN RIGHTS.—No elec2 tion may be made under paragraph (1) unless the 

3 specified electing individual makes an irrevocable 

4 waiver of any right under any treaty of the United 

5 States which would preclude assessment or collection 

6 of any tax imposed by reason of this section. 

7 ‘‘(7) ELECTIONS.—An election under paragraph 

8 (1) shall only apply to property described in the elec9 tion and, once made, is irrevocable. 

10 ‘‘(8) INTEREST.—For purposes of section 6601, 

11 the last date for the payment of tax shall be deter12 mined without regard to the election under this sub13 section. 

14 ‘‘(9) SPECIAL RULE IF ELECTION OF RESI15 DENCY-BASED INCOME TAX TERMINATES BEFORE

16 PROPERTY IS DISPOSED OF.—In the case of any 

17 property with respect to which an election under this 

18 subsection has been made, if the election under sec19 tion 899 with respect to the electing individual ter20 minates before the beginning of the taxable year in 

21 which such property is disposed of, this section shall 

22 not apply to such property. 

23 ‘‘(f) SPECIAL RULES.— 


ssavage on LAPJG3WLY3PROD with BILLS
14 

•HR 10468 IH

1 ‘‘(1) TERMINATION OF DEFERRALS, ETC.—In 

2 the case of any specified electing individual, notwith3 standing any other provision of this title— 

4 ‘‘(A) any time period for acquiring prop5 erty which would result in the reduction in the 

6 amount of gain recognized with respect to prop7 erty disposed of by the electing individual shall 

8 terminate on the day before the election date, 

9 and 

10 ‘‘(B) any extension of time for payment of 

11 tax shall cease to apply on the day before the 

12 election date and the unpaid portion of such tax 

13 shall be due and payable at the time and in the 

14 manner prescribed by the Secretary. 

15 ‘‘(2) STEP-UP IN BASIS.—Solely for purposes of 

16 determining any tax imposed by reason of subsection 

17 (a), property which was held by an individual on the 

18 date the individual most recently became a resident 

19 of the United States (within the meaning of section 

20 7701(b)) shall be treated as having a basis on such 

21 date of not less than the fair market value of such 

22 property on such date. The preceding sentence shall 

23 not apply if the individual elects not to have such 

24 sentence apply. Such an election, once made, shall 

25 be irrevocable. 


ssavage on LAPJG3WLY3PROD with BILLS
15 

•HR 10468 IH

1 ‘‘(3) SEPARATE APPLICATION TO EACH ELEC2 TION.—In the case of any individual who makes 

3 more than 1 election under section 899, this section 

4 shall be applied separately with respect to each such 

5 election. 

6 ‘‘(g) TRANSITIONAL RULE.— 

7 ‘‘(1) IN GENERAL.—This section, and sub8 section (a)(2) and (d)(2) of section 899, shall not 

9 apply to— 

10 ‘‘(A) any individual if— 

11 ‘‘(i) as of the introduction date, such 

12 individual meets the ordinary residence 

13 test under paragraph (2), 

14 ‘‘(ii) such individual has not been a 

15 resident of the United States (as defined in 

16 section 7701(b)(1)(A)(ii)) for at least 3 of 

17 the last 5 taxable years ending before the 

18 introduction date, and 

19 ‘‘(iii) such individual certifies under 

20 penalty of perjury that the electing indi21 vidual has met the requirements of this 

22 title for the last 3 taxable years ending be23 fore the introduction date and submits 

24 such evidence of such compliance as the 

25 Secretary may require, and 


ssavage on LAPJG3WLY3PROD with BILLS
16 

•HR 10468 IH

1 ‘‘(B) any individual who has not been a 

2 resident of the United States (as defined in sec3 tion 7701(b)(1)(A)(ii)) at any time during the 

4 period beginning on the later of the date such 

5 individual attains age 25 or March 18, 2010, 

6 and ending on the date of the enactment of this 

7 section (and such individual shall be treated as 

8 described in this subparagraph without regard 

9 to whether or not such individual has met the 

10 requirements of this title at any time). 

11 ‘‘(2) ORDINARY RESIDENCE TEST.—An indi12 vidual meets the ordinary residence test if such indi13 vidual is a tax resident of a foreign country and 

14 such foreign country is the place where such indi15 vidual regularly, normally, or customarily lives. 

16 ‘‘(3) INTRODUCTION DATE.—For purposes of 

17 this subsection, the term ‘introduction date’ means 

18 the date of the introduction of the bill which, upon 

19 enactment, enacted this section. 

20 ‘‘SEC. 899B. CERTIFICATES OF NONRESIDENCY. 

21 ‘‘(a) IN GENERAL.—Upon application, the Secretary 

22 shall issue a certificate of nonresidency— 

23 ‘‘(1) to any electing individual if the Secretary 

24 determines that an election by such individual under 

25 section 899 is in effect, and 


ssavage on LAPJG3WLY3PROD with BILLS
17 

•HR 10468 IH

1 ‘‘(2) to any citizen of the United States born in 

2 a foreign country after the date of the enactment of 

3 this section. 

4 ‘‘(b) TERMINATION OF CERTIFICATE.—A certificate 

5 of nonresidency issued under this section shall terminate 

6 on the first date after such issuance with respect to which 

7 the individual to whom such certificate is issued— 

8 ‘‘(1) is a resident of the United States (as de9 fined in section 7701(b)(1)(A)(ii)), or 

10 ‘‘(2) in the case of an individual described in 

11 subsection (a)(1), otherwise ceases to have an elec12 tion in effect under section 899. 

13 ‘‘(c) PUBLICATION OF CERTIFICATE NUMBERS.— 

14 The Secretary shall maintain a searchable public database 

15 and shall— 

16 ‘‘(1) promptly upon the issuance of any certifi17 cate of nonresidency, update such database to in18 clude the certificate number and date of issuance of 

19 such certificate, and 

20 ‘‘(2) promptly upon the termination of any cer21 tificate of nonresidency, update such database to in22 dicate the termination of such certificate and the 

23 date of such termination. 

24 ‘‘(d) USER FEES.— 


ssavage on LAPJG3WLY3PROD with BILLS
18 

•HR 10468 IH

1 ‘‘(1) IN GENERAL.—The Secretary shall impose 

2 a user fee of $100 per application under this section. 

3 Fees received under this subsection shall be available 

4 to the Secretary (without need of further appropria5 tion) for the costs of processing applications under 

6 this section. 

7 ‘‘(2) INFLATION ADJUSTMENT.—In the case of 

8 any calendar year beginning after 2025, the $100 

9 amount in paragraph (1) shall be increased by an 

10 amount equal to— 

11 ‘‘(A) such dollar amount, multiplied by 

12 ‘‘(B) the cost-of-living adjustment deter13 mined under section 1(f)(3) for such calendar 

14 year determined by substituting ‘2024’ for 

15 ‘2016’ in subparagraph (A)(ii) thereof. 

16 If any increase under the preceding sentence is not 

17 a multiple of $5, such increase shall be rounded to 

18 next lowest multiple of $5. 

19 ‘‘(e) REFERENCES.—Except where the context clearly 

20 indicates to the contrary, any reference in any provision 

21 of law to a certificate of nonresidency issued under this 

22 section shall include only such certificates which have not 

23 been terminated. 


ssavage on LAPJG3WLY3PROD with BILLS
19 

•HR 10468 IH

1 ‘‘SEC. 899C. REGULATIONS. 

2 ‘‘The Secretary shall prescribe such regulations or 

3 other guidance as may be necessary or appropriate to 

4 carry out the purposes of this subpart.’’. 

5 (b) CLERICAL AMENDMENT.—The table of subparts 

6 for part II of subchapter N of chapter 1 of such Code 

7 is amended by adding at the end the following new item: 

‘‘SUBPART E—RESIDENCY-BASED INCOME TAX FOR NONRESIDENT CITIZENS

OF THE UNITED STATES’’. 

8 (c) EFFECTIVE DATE.—The amendments made by 

9 this section shall apply to elections made after the date 

10 of the enactment of this Act for taxable years ending after 

11 such date. 

12 SEC. 3. PARTICIPATING FOREIGN FINANCIAL INSTITU13 TIONS PROHIBITED FROM DISCRIMINATING 

14 AGAINST NONRESIDENT UNITED STATES 

15 CITIZENS. 

16 (a) IN GENERAL.—Section 1471(b)(1) of the Internal 

17 Revenue Code of 1986 is amended by striking ‘‘and’’ at 

18 the end of subparagraph (E), by striking the period at 

19 the end of subparagraph (F) and inserting ‘‘, and’’, and 

20 by inserting after subparagraph (F) the following new 

21 subparagraph: 

22 ‘‘(G) not to have policies or practices that 

23 discriminate against opening or maintaining fi24 nancial accounts for individuals who are citizens 


ssavage on LAPJG3WLY3PROD with BILLS
20 

•HR 10468 IH

1 of the United States and residents of the coun2 try in which the financial account is to be 

3 opened or maintained.’’. 

4 (b) EFFECTIVE DATE.— 

5 (1) IN GENERAL.—The amendments made by 

6 this section shall take effect on the date of the en7 actment of this Act. 

8 (2) TRANSITION RULE.—During the 1-year pe9 riod beginning on the date of the enactment of this 

10 Act, an agreement shall not fail to be treated as de11 scribed in section 1471(b)(1) of the Internal Rev12 enue Code of 1986 solely by reason failing to include 

13 the requirement of subparagraph (G) thereof if the 

14 institution entering into such agreement satisfies 

15 such requirement at all times during such period 

16 without regard to whether such requirement is in17 cluded in such agreement. 

Æ 


ssavage on LAPJG3WLY3PROD with BILLS