I

104TH CONGRESS

1ST SESSION H. R. 2012

To amend the Internal Revenue Code of 1986 to revise the income, estate,

and gift tax rules applicable to individuals who lose United States citizenship.

IN THE HOUSE OF REPRESENTATIVES

JULY 11, 1995

Mr. CREMEANS 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 revise

the income, estate, and gift tax rules applicable to individuals who lose United States citizenship.

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 ‘‘Expatriation Tax Act

5 of 1995’’.
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1 SEC. 2. REVISION OF INCOME, ESTATE, AND GIFT TAXES ON

2 INDIVIDUALS WHO LOSE UNITED STATES

3 CITIZENSHIP.

4 (a) IN GENERAL.—Subsection (a) of section 877 of

5 the Internal Revenue Code of 1986 is amended to read

6 as follows:

7 ‘‘(a) TREATMENT OF EXPATRIATES.—

8 ‘‘(1) IN GENERAL.—Every nonresident alien in9 dividual who, within the 10-year period immediately

10 preceding the close of the taxable year, lost United

11 States citizenship, unless such loss did not have for

12 1 of its principal purposes the avoidance of taxes

13 under this subtitle or subtitle B, shall be taxable for

14 such taxable year in the manner provided in sub15 section (b) if the tax imposed pursuant to such sub16 section exceeds the tax which, without regard to this

17 section, is imposed pursuant to section 871.

18 ‘‘(2) CERTAIN INDIVIDUALS TREATED AS HAV19 ING TAX AVOIDANCE PURPOSE.—For purposes of

20 paragraph (1), an individual shall be treated as hav21 ing a principal purpose to avoid such taxes if—

22 ‘‘(A) the average annual net income tax

23 (as defined in section 38(c)(1)) of such individ24 ual for the period of 5 taxable years ending be25 fore the date of the loss of United States citi26 zenship is greater than $100,000, or
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1 ‘‘(B) the net worth of the individual as of

2 such date is $500,000 or more.

3 In the case of the loss of United States citizenship

4 in any calendar year after 1996, such $100,000 and

5 $500,000 amounts shall be increased by an amount

6 equal to such dollar amount multiplied by the cost7 of-living adjustment determined under section

8 1(f)(3) for such calendar year by substituting ‘1994’

9 for ‘1992’ in subparagraph (B) thereof. Any in10 crease under the preceding sentence shall be round11 ed to the nearest multiple of $1,000.’’

12 (b) EXCEPTIONS.—

13 (1) IN GENERAL.—Section 877 of such Code is

14 amended by striking subsection (d), by redesignating

15 subsection (c) as subsection (d), and by inserting

16 after subsection (b) the following new subsection:

17 ‘‘(c) TAX AVOIDANCE NOT PRESUMED IN CERTAIN

18 CASES.—

19 ‘‘(1) IN GENERAL.—Subsection (a)(2) shall not

20 apply to an individual if—

21 ‘‘(A) such individual is described in a sub22 paragraph of paragraph (2) of this subsection,

23 and

24 ‘‘(B) within the 1-year period beginning on

25 the date of the loss of United States citizenship,
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1 such individual submits a ruling request for the

2 Secretary’s determination as to whether such

3 loss has for 1 of its principal purposes the

4 avoidance of taxes under this subtitle or subtitle

5 B.

6 ‘‘(2) INDIVIDUALS DESCRIBED.—

7 ‘‘(A) DUAL CITIZENSHIP, ETC.—An indi8 vidual is described in this subparagraph if—

9 ‘‘(i) the individual became at birth a

10 citizen of the United States and a citizen

11 of another country and continues to be a

12 citizen of such other country, or

13 ‘‘(ii) the individual becomes (not later

14 than the close of a reasonable period after

15 loss of United States citizenship) a citizen

16 of the country in which—

17 ‘‘(I) such individual was born,

18 ‘‘(II) if such individual is mar19 ried, such individual’s spouse was

20 born, or

21 ‘‘(III) either of such individual’s

22 parents were born.

23 ‘‘(B) LONG-TERM FOREIGN RESIDENTS.—

24 An individual is described in this subparagraph

25 if, for each year in the 10-year period ending on
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1 the date of loss of United States citizenship, the

2 individual was present in the United States for

3 30 days or less. The rule of section

4 7701(b)(3)(D)(ii) shall apply for purposes of

5 this subparagraph.

6 ‘‘(C) RENUNCIATION UPON REACHING AGE

7 OF MAJORITY.—An individual is described in

8 this subparagraph if the individual’s loss of

9 United States citizenship occurs before such individual attains age 181 10 ⁄2.

11 ‘‘(D) INDIVIDUALS SPECIFIED IN REGULA12 TIONS.—An individual is described in this sub13 paragraph if the individual is described in a

14 category of individuals prescribed by regulation

15 by the Secretary.’’

16 (2) TECHNICAL AMENDMENT.—Paragraph (1)

17 of section 877(b) of such Code is amended by strik18 ing ‘‘subsection (c)’’ and inserting ‘‘subsection (d)’’.

19 (c) TREATMENT OF PROPERTY DISPOSED OF IN

20 NONRECOGNITION TRANSACTIONS; TREATMENT OF DIS21 TRIBUTIONS FROM CERTAIN CONTROLLED FOREIGN

22 CORPORATIONS.—Subsection (d) of section 877 of such

23 Code, as redesignated by subsection (b), is amended to

24 read as follows:
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1 ‘‘(d) SPECIAL RULES FOR SOURCE, ETC.—For pur2 poses of subsection (b)—

3 ‘‘(1) SOURCE RULES.—The following items of

4 gross income shall be treated as income from sources

5 within the United States:

6 ‘‘(A) SALE OF PROPERTY.—Gains on the

7 sale or exchange of property (other than stock

8 or debt obligations) located in the United

9 States.

10 ‘‘(B) STOCK OR DEBT OBLIGATIONS.—

11 Gains on the sale or exchange of stock issued

12 by a domestic corporation or debt obligations of

13 United States persons or of the United States,

14 a State or political subdivision thereof, or the

15 District of Columbia.

16 ‘‘(C) INCOME OR GAIN DERIVED FROM

17 CONTROLLED FOREIGN CORPORATION.—Any in18 come or gain derived from stock in a foreign

19 corporation but only—

20 ‘‘(i) if the individual losing United

21 States citizenship owned (within the mean22 ing of section 958(a)), or is considered as

23 owning (by applying the ownership rules of

24 section 958(b)), at any time during the 2-

25 year period ending on the date of the loss
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1 of United States citizenship, more than 50

2 percent of—

3 ‘‘(I) the total combined voting

4 power of all classes of stock entitled

5 to vote of such corporation, or

6 ‘‘(II) the total value of the stock

7 of such corporation, and

8 ‘‘(ii) to the extent such income or gain

9 does not exceed the earnings and profits

10 attributable to such stock which were

11 earned or accumulated before the loss of

12 citizenship and during periods that the

13 ownership requirements of clause (i) are

14 met.

15 ‘‘(2) GAIN RECOGNITION ON CERTAIN EX16 CHANGES.—

17 ‘‘(A) IN GENERAL.—In the case of any ex18 change of property to which this paragraph ap19 plies, notwithstanding any other provision of

20 this title, such property shall be treated as sold

21 for its fair market value on the date of such ex22 change, and any gain shall be recognized for

23 the taxable year which includes such date.

24 ‘‘(B) EXCHANGES TO WHICH PARAGRAPH

25 APPLIES.—This paragraph shall apply to any
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1 exchange during the 10-year period described in

2 subsection (a) if—

3 ‘‘(i) gain would not (but for this para4 graph) be recognized on such exchange in

5 whole or in part for purposes of this sub6 title,

7 ‘‘(ii) income derived from such prop8 erty was from sources within the United

9 States (or, if no income was so derived,

10 would have been from such sources), and

11 ‘‘(iii) income derived from the prop12 erty acquired in the exchange would be

13 from sources outside the United States.

14 ‘‘(C) EXCEPTION.—Subparagraph (A)

15 shall not apply if the individual enters into an

16 agreement with the Secretary which specifies

17 that any income or gain derived from the prop18 erty acquired in the exchange (or any other

19 property which has a basis determined in whole

20 or part by reference to such property) during

21 such 10-year period shall be treated as from

22 sources within the United States. If the prop23 erty transferred in the exchange is disposed of

24 by the person acquiring such property, such

25 agreement shall terminate and any gain which
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1 was not recognized by reason of such agreement

2 shall be recognized as of the date of such dis3 position.

4 ‘‘(D) SECRETARY MAY EXTEND PERIOD.—

5 To the extent provided in regulations prescribed

6 by the Secretary, subparagraph (B) shall be ap7 plied by substituting the 15-year period begin8 ning 5 years before the loss of United States

9 citizenship for the 10-year period referred to

10 therein.

11 ‘‘(E) SECRETARY MAY REQUIRE RECOGNI12 TION OF GAIN IN CERTAIN CASES.—To the ex13 tent provided in regulations prescribed by the

14 Secretary—

15 ‘‘(i) the removal of appreciated tan16 gible personal property from the United

17 States, and

18 ‘‘(ii) any other occurrence which

19 (without recognition of gain) results in a

20 change in the source of the income or gain

21 from property from sources within the

22 United States to sources outside the

23 United States,

24 shall be treated as an exchange to which this

25 paragraph applies.
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1 ‘‘(3) SUBSTANTIAL DIMINISHING OF RISKS OF

2 OWNERSHIP.—For purposes of determining whether

3 this section applies to any gain on the sale or ex4 change of any property, the running of the 10-year

5 period described in subsection (a) shall be suspended

6 for any period during which the individual’s risk of

7 loss with respect to the property is substantially di8 minished by—

9 ‘‘(A) the holding of a put with respect to

10 such property (or similar property),

11 ‘‘(B) the holding by another person of a

12 right to acquire the property, or

13 ‘‘(C) a short sale or any other trans14 action.’’

15 (d) CREDIT FOR FOREIGN TAXES IMPOSED ON

16 UNITED STATES SOURCE INCOME.—

17 (1) Subsection (b) of section 877 of such Code

18 is amended by adding at the end the following new

19 sentence: ‘‘The tax imposed solely by reason of this

20 section shall be reduced (but not below zero) by the

21 amount of any income, war profits, and excess prof22 its taxes (within the meaning of section 903) paid to

23 any foreign country or possession of the United

24 States on any income of the taxpayer on which tax

25 is imposed solely by reason of this section.’’
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1 (2) Subsection (a) of section 877 of such Code,

2 as amended by subsection (a), is amended by insert3 ing ‘‘(after any reduction in such tax under the last

4 sentence of such subsection)’’ after ‘‘such sub5 section’’.

6 (e) COMPARABLE ESTATE AND GIFT TAX TREAT7 MENT.—

8 (1) ESTATE TAX.—

9 (A) IN GENERAL.—Subsection (a) of sec10 tion 2107 of such Code is amended to read as

11 follows:

12 ‘‘(a) TREATMENT OF EXPATRIATES.—

13 ‘‘(1) RATE OF TAX.—A tax computed in accord14 ance with the table contained in section 2001 is

15 hereby imposed on the transfer of the taxable estate,

16 determined as provided in section 2106, of every de17 cedent nonresident not a citizen of the United States

18 if, within the 10-year period ending with the date of

19 death, such decedent lost United States citizenship,

20 unless such loss did not have for 1 of its principal

21 purposes the avoidance of taxes under this subtitle

22 or subtitle A.

23 ‘‘(2) CERTAIN INDIVIDUALS TREATED AS HAV24 ING TAX AVOIDANCE PURPOSE.—
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1 ‘‘(A) IN GENERAL.—For purposes of para2 graph (1), an individual shall be treated as hav3 ing a principal purpose to avoid such taxes if

4 such individual is so treated under section

5 877(a)(2).

6 ‘‘(B) EXCEPTION.—Subparagraph (A)

7 shall not apply to a decedent meeting the re8 quirements of section 877(c)(1).’’

9 (B) CREDIT FOR FOREIGN DEATH

10 TAXES.—Subsection (c) of section 2107 of such

11 Code is amended by redesignating paragraph

12 (2) as paragraph (3) and by inserting after

13 paragraph (1) the following new paragraph:

14 ‘‘(2) CREDIT FOR FOREIGN DEATH TAXES.—

15 ‘‘(A) IN GENERAL.—The tax imposed by

16 subsection (a) shall be credited with the amount

17 of any estate, inheritance, legacy, or succession

18 taxes actually paid to any foreign country in re19 spect of any property which is included in the

20 gross estate solely by reason of subsection (b).

21 ‘‘(B) LIMITATION ON CREDIT.—The credit

22 allowed by subparagraph (A) for such taxes

23 paid to a foreign country shall not exceed the

24 lesser of—
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1 ‘‘(i) the amount which bears the same

2 ratio to the amount of such taxes actually

3 paid to such foreign country in respect of

4 property included in the gross estate as the

5 value of the property included in the gross

6 estate solely by reason of subsection (b)

7 bears to the value of all property subjected

8 to such taxes by such foreign country, or

9 ‘‘(ii) such property’s proportionate

10 share of the excess of—

11 ‘‘(I) the tax imposed by sub12 section (a), over

13 ‘‘(II) the tax which would be im14 posed by section 2101 but for this

15 section.

16 ‘‘(C) PROPORTIONATE SHARE.—For pur17 poses of subparagraph (B), a property’s propor18 tionate share is the percentage which the value

19 of the property which is included in the gross

20 estate solely by reason of subsection (b) bears

21 to the total value of the gross estate.’’

22 (C) EXPANSION OF INCLUSION IN GROSS

23 ESTATE OF STOCK OF FOREIGN CORPORA24 TIONS.—Paragraph (2) of section 2107(b) of

25 such Code is amended by striking ‘‘more than
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1 50 percent of’’ and all that follows and insert2 ing ‘‘more than 50 percent of—

3 ‘‘(A) the total combined voting power of all

4 classes of stock entitled to vote of such corpora5 tion, or

6 ‘‘(B) the total value of the stock of such

7 corporation,’’.

8 (2) GIFT TAX.—

9 (A) IN GENERAL.—Paragraph (3) of sec10 tion 2501(a) of such Code is amended to read

11 as follows:

12 ‘‘(3) EXCEPTION.—

13 ‘‘(A) CERTAIN INDIVIDUALS.—Paragraph

14 (2) shall not apply in the case of a donor who,

15 within the 10-year period ending with the date

16 of transfer, lost United States citizenship, un17 less such loss did not have for 1 of its principal

18 purposes the avoidance of taxes under this sub19 title or subtitle A.

20 ‘‘(B) CERTAIN INDIVIDUALS TREATED AS

21 HAVING TAX AVOIDANCE PURPOSE.—For pur22 poses of subparagraph (A), an individual shall

23 be treated as having a principal purpose to

24 avoid such taxes if such individual is so treated

25 under section 877(a)(2).
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1 ‘‘(C) EXCEPTION FOR CERTAIN INDIVID2 UALS.—Subparagraph (B) shall not apply to a

3 decedent meeting the requirements of section

4 877(c)(1).

5 ‘‘(D) CREDIT FOR FOREIGN GIFT TAXES.—

6 The tax imposed by this section solely by reason

7 of this paragraph shall be credited with the

8 amount of any gift tax actually paid to any for9 eign country in respect of any gift which is tax10 able under this section solely by reason of this

11 paragraph.’’

12 (f) COMPARABLE TREATMENT OF LAWFUL PERMA13 NENT RESIDENTS WHO CEASE TO BE TAXED AS RESI14 DENTS.—

15 (1) IN GENERAL.—Section 877 of such Code is

16 amended by redesignating subsection (e) as sub17 section (f) and by inserting after subsection (d) the

18 following new subsection:

19 ‘‘(e) COMPARABLE TREATMENT OF LAWFUL PERMA20 NENT RESIDENTS WHO CEASE TO BE TAXED AS RESI21 DENTS.—

22 ‘‘(1) IN GENERAL.—Any long-term resident of

23 the United States who—
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1 ‘‘(A) ceases to be a lawful permanent resi2 dent of the United States (within the meaning

3 of section 7701(b)(6)), or

4 ‘‘(B) commences to be treated as a resi5 dent of a foreign country under the provisions

6 of a tax treaty between the United States and

7 the foreign country and who does not waive the

8 benefits of such treaty applicable to residents of

9 the foreign country,

10 shall be treated for purposes of this section and sec11 tions 2107, 2501, and 6039F in the same manner

12 as if such resident were a citizen of the United

13 States who lost United States citizenship on the date

14 of such cessation or commencement.

15 ‘‘(2) LONG-TERM RESIDENT.—For purposes of

16 this subsection, the term ‘long-term resident’ means

17 any individual (other than a citizen of the United

18 States) who is a lawful permanent resident of the

19 United States in at least 8 taxable years during the

20 period of 15 taxable years ending with the taxable

21 year during which the event described in subpara22 graph (A) or (B) of paragraph (1) occurs. For pur23 poses of the preceding sentence, an individual shall

24 not be treated as a lawful permanent resident for

25 any taxable year if such individual is treated as a
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1 resident of a foreign country for the taxable year

2 under the provisions of a tax treaty between the

3 United States and the foreign country and does not

4 waive the benefits of such treaty applicable to resi5 dents of the foreign country.

6 ‘‘(3) SPECIAL RULES.—

7 ‘‘(A) EXCEPTIONS NOT TO APPLY.—Sub8 section (c) shall not apply to an individual who

9 is treated as provided in paragraph (1).

10 ‘‘(B) STEP-UP IN BASIS.—Solely for pur11 poses of determining any tax imposed by reason

12 of this subsection, property which was held by

13 the long-term resident on the date the individ14 ual first became a resident of the United States

15 shall be treated as having a basis on such date

16 of not less than the fair market value of such

17 property on such date. The preceding sentence

18 shall not apply if the individual elects not to

19 have such sentence apply. Such an election,

20 once made, shall be irrevocable.

21 ‘‘(4) AUTHORITY TO EXEMPT INDIVIDUALS.—

22 This subsection shall not apply to an individual who

23 is described in a category of individuals prescribed

24 by regulation by the Secretary.
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1 ‘‘(5) REGULATIONS.—The Secretary shall pre2 scribe such regulations as may be appropriate to

3 carry out this subsection, including regulations pro4 viding for the application of this subsection in cases

5 where an alien individual becomes a resident of the

6 United States during the 10-year period after being

7 treated as provided in paragraph (1).’’

8 (2) CONFORMING AMENDMENTS.—

9 (A) Section 2107 of such Code is amended

10 by striking subsection (d), by redesignating sub11 section (e) as subsection (d), and by inserting

12 after subsection (d) (as so redesignated) the fol13 lowing new subsection:

14 ‘‘(e) CROSS REFERENCE.—

‘‘For comparable treatment of long-term lawful

permanent residents who ceased to be taxed as residents, see section 877(e).’’

15 (B) Paragraph (3) of section 2501(a) of

16 such Code (as amended by subsection (e)) is

17 amended by adding at the end the following

18 new subparagraph:

19 ‘‘(E) CROSS REFERENCE.—

‘‘For comparable treatment of long-term lawful

permanent residents who ceased to be taxed as residents, see section 877(e).’’

20 (g) EFFECTIVE DATE.—

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

22 this section shall apply to—
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1 (A) individuals losing United States citi2 zenship (within the meaning of section 877 of

3 the Internal Revenue Code of 1986) on or after

4 February 6, 1995, and

5 (B) long-term residents of the United

6 States with respect to whom an event described

7 in subparagraph (A) or (B) of section 877(e)(1)

8 of such Code occurs on or after June 13, 1995.

9 (2) SPECIAL RULE.—

10 (A) IN GENERAL.—In the case of an indi11 vidual who performed an act of expatriation

12 specified in paragraph (1), (2), (3), or (4) of

13 section 349(a) of the Immigration and Nation14 ality Act (8 U.S.C. 1481(a)(1)–(4)) before Feb15 ruary 6, 1995, but who did not, on or before

16 such date, furnish to the United States Depart17 ment of State a signed statement of voluntary

18 relinquishment of United States nationality con19 firming the performance of such act, the

20 amendments made by this section shall apply to

21 such individual except that—

22 (i) the 10-year period described in

23 section 877(a) of such Code shall not ex24 pire before the end of the 10-year period
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1 beginning on the date such statement is so

2 furnished, and

3 (ii) the 1-year period referred to in

4 section 877(c) of such Code, as amended

5 by this section, shall not expire before the

6 date which is 1 year after the date of the

7 enactment of this Act.

8 (B) EXCEPTION.—Subparagraph (A) shall

9 not apply if the individual establishes to the

10 satisfaction of the Secretary of the Treasury

11 that such loss of United States citizenship oc12 curred before February 6, 1994.

13 SEC. 3. INFORMATION ON INDIVIDUALS LOSING UNITED

14 STATES CITIZENSHIP.

15 (a) IN GENERAL.—Subpart A of part III of sub16 chapter A of chapter 61 of the Internal Revenue Code of

17 1986 is amended by inserting after section 6039E the fol18 lowing new section:

19 ‘‘SEC. 6039F. INFORMATION ON INDIVIDUALS LOSING

20 UNITED STATES CITIZENSHIP.

21 ‘‘(a) IN GENERAL.—Notwithstanding any other pro22 vision of law, any individual who loses United States citi23 zenship (within the meaning of section 877(a)) shall pro24 vide a statement which includes the information described

25 in subsection (b). Such statement shall be—
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1 ‘‘(1) provided not later than the earliest date of

2 any act referred to in subsection (c), and

3 ‘‘(2) provided to the person or court referred to

4 in subsection (c) with respect to such act.

5 ‘‘(b) INFORMATION TO BE PROVIDED.—Information

6 required under subsection (a) shall include—

7 ‘‘(1) the taxpayer’s TIN,

8 ‘‘(2) the mailing address of such individual’s

9 principal foreign residence,

10 ‘‘(3) the foreign country in which such individ11 ual is residing,

12 ‘‘(4) the foreign country of which such individ13 ual is a citizen,

14 ‘‘(5) in the case of an individual having a net

15 worth of at least the dollar amount applicable under

16 section 877(a)(2)(B), information detailing the as17 sets and liabilities of such individual, and

18 ‘‘(6) such other information as the Secretary

19 may prescribe.

20 ‘‘(c) ACTS DESCRIBED.—For purposes of this sec21 tion, the acts referred to in this subsection are—

22 ‘‘(1) the individual’s renunciation of his United

23 States nationality before a diplomatic or consular of24 ficer of the United States pursuant to paragraph (5)
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1 of section 349(a) of the Immigration and Nationality

2 Act (8 U.S.C. 1481(a)(5)),

3 ‘‘(2) the individual’s furnishing to the United

4 States Department of State a signed statement of

5 voluntary relinquishment of United States national6 ity confirming the performance of an act of expatria7 tion specified in paragraph (1), (2), (3), or (4) of

8 section 349(a) of the Immigration and Nationality

9 Act (8 U.S.C. 1481(a)(1)–(4)),

10 ‘‘(3) the issuance by the United States Depart11 ment of State of a certificate of loss of nationality

12 to the individual, or

13 ‘‘(4) the cancellation by a court of the United

14 States of a naturalized citizen’s certificate of natu15 ralization.

16 ‘‘(d) PENALTY.—Any individual failing to provide a

17 statement required under subsection (a) shall be subject

18 to a penalty for each year (of the 10-year period beginning

19 on the date of loss of United States citizenship) during

20 any portion of which such failure continues in an amount

21 equal to the greater of—

22 ‘‘(1) 5 percent of the tax required to be paid

23 under section 877 for the taxable year ending during

24 such year, or

25 ‘‘(2) $1,000,
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1 unless it is shown that such failure is due to reasonable

2 cause and not to willful neglect.

3 ‘‘(e) INFORMATION TO BE PROVIDED TO SEC4 RETARY.—Notwithstanding any other provision of law—

5 ‘‘(1) any Federal agency or court which collects

6 (or is required to collect) the statement under sub7 section (a) shall provide to the Secretary—

8 ‘‘(A) a copy of any such statement, and

9 ‘‘(B) the name (and any other identifying

10 information) of any individual refusing to com11 ply with the provisions of subsection (a),

12 ‘‘(2) the Secretary of State shall provide to the

13 Secretary a copy of each certificate as to the loss of

14 American nationality under section 358 of the Immi15 gration and Nationality Act which is approved by

16 the Secretary of State, and

17 ‘‘(3) the Federal agency primarily responsible

18 for administering the immigration laws shall provide

19 to the Secretary the name of each lawful permanent

20 resident of the United States (within the meaning of

21 section 7701(b)(6)) whose status as such has been

22 revoked or has been administratively or judicially de23 termined to have been abandoned.

24 Notwithstanding any other provision of law, not later than

25 30 days after the close of each calendar quarter, the Sec-
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1 retary shall publish in the Federal Register the name of

2 each individual losing United States citizenship (within

3 the meaning of section 877(a)) with respect to whom the

4 Secretary receives information under the preceding sen5 tence during such quarter.

6 ‘‘(f) REPORTING BY LONG-TERM LAWFUL PERMA7 NENT RESIDENTS WHO CEASE TO BE TAXED AS RESI8 DENTS.—In lieu of applying the last sentence of sub9 section (a), any individual who is required to provide a

10 statement under this section by reason of section

11 877(e)(1) shall provide such statement with the return of

12 tax imposed by chapter 1 for the taxable year during

13 which the event described in such section occurs.

14 ‘‘(g) EXEMPTION.—The Secretary may by regula15 tions exempt any class of individuals from the require16 ments of this section if he determines that applying this

17 section to such individuals is not necessary to carry out

18 the purposes of this section.’’

19 (b) CLERICAL AMENDMENT.—The table of sections

20 for such subpart A is amended by inserting after the item

21 relating to section 6039E the following new item:

‘‘Sec. 6039F. Information on individuals losing United States citizenship.’’

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

23 this section shall apply to—
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1 (1) individuals losing United States citizenship

2 (within the meaning of section 877 of the Internal

3 Revenue Code of 1986) after the date of the enact4 ment of this Act, and

5 (2) long-term residents of the United States

6 with respect to whom an event described in subpara7 graph (A) or (B) of section 877(e)(1) of such Code

8 occurs after such date.

9 SEC. 4. REPORT ON TAX COMPLIANCE BY UNITED STATES

10 CITIZENS AND RESIDENTS LIVING ABROAD.

11 Not later than 90 days after the date of the enact12 ment of this Act, the Secretary of the Treasury shall pre13 pare and submit to the Committee on Ways and Means

14 of the House of Representatives and the Committee on

15 Finance of the Senate a report—

16 (1) describing the compliance with subtitle A of

17 the Internal Revenue Code of 1986 by citizens and

18 lawful permanent residents of the United States

19 (within the meaning of section 7701(b)(6) of such

20 Code) residing outside the United States, and

21 (2) recommending measures to improve such

22 compliance (including improved coordination be23 tween executive branch agencies).

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