A bill to amend the Internal Revenue Code of 1986 to prevent the continued use of renouncing United States citizenship as a device for avoiding United States taxes.

Summary

Amends the Internal Revenue Code to establish that all property of "covered expatriates" shall be treated as sold on the day before the "expatriation date" for its fair market value, and that gain and loss shall be taken into account for the taxable year of the sale (with proper subsequent adjustment). Defines "expatriate" and "expatriation date." Permits an individual to make an irrevocable decision to defer the additional tax attributable to such property provided that adequate security is furnished and that the individual waives any rights under treaties of the United States that would preclude assessment or collection of relevant tax. Excludes certain "United States real property interests" and interest in certain retirement plans from counting as sold under this Act. Establishes special rules applicable to "covered expatriates'" interests in trusts and qualified trusts, including a tax in instances of the latter. Sets forth that such tax shall be replaced by another tax under certain delineated conditions, including if a trust ceases to be a qualified trust. Imposes a tax on "covered gifts and bequests" of more than $10,000 from expatriates to American citizens and residents, with certain specified exceptions.

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Timeline

1. 22 July 2002

   Introduced

   Read twice and referred to the Committee on Finance.

   Source: IntroReferral

2. 22 July 2002

   Introduced

   Introduced in Senate

   Source: IntroReferral

Votes

No vote records are attached yet.

Versions

• Introduced in Senate · 22 July 2002 · Official file

Documents

3 official files

• Introduced in Senate (text)

  Introduced in Senate · EN · 22 July 2002

  ViewDownloadOpen at official source

• Introduced in Senate (PDF)

  Introduced in Senate · EN · 22 July 2002

  ViewDownloadOpen at official source

• Introduced in Senate

  summary · EN · 22 July 2002

  Open at official source

Sponsors

• Rep. Harkin, Tom [D-IA-5] · D · Sponsor
• Sen. Stabenow, Debbie [D-MI] · D · Sponsor
• · ssfi00 · Standing

Related records

• related to → To amend the Internal Revenue Code of 1986 to prevent the continued use of renouncing United States citizenship as a device for avoiding United States taxes.