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All property of a covered expatriate shall be treated as sold on the day before the expatriation date for its fair market value.

In the case of any sale under paragraph (1)—

If the taxpayer elects the application of this subsection with respect to any property treated as sold by reason of subsection (a), the time for payment of the additional tax attributable to such property shall be extended until the due date of the return for the taxable year in which such property is disposed of (or, in the case of property disposed of in a transaction in which gain is not recognized in whole or in part, until such other date as the Secretary may prescribe).

For purposes of paragraph (1), the additional tax attributable to any property is an amount which bears the same ratio to the additional tax imposed by this chapter for the taxable year solely by reason of subsection (a) as the gain taken into account under subsection (a) with respect to such property bears to the total gain taken into account under subsection (a) with respect to all property to which subsection (a) applies.

The due date for payment of tax may not be extended under this subsection later than the due date for the return of tax imposed by this chapter for the taxable year which includes the date of death of the expatriate (or, if earlier, the time that the security provided with respect to the property fails to meet the requirements of paragraph (4), unless the taxpayer corrects such failure within the time specified by the Secretary).

No election may be made under paragraph (1) unless the taxpayer makes an irrevocable waiver of any right under any treaty of the United States which would preclude assessment or collection of any tax imposed by reason of this section.

An election under paragraph (1) shall only apply to property described in the election and, once made, is irrevocable.

For purposes of section 6601, the last date for the payment of tax shall be determined without regard to the election under this subsection.

In the case of any deferred compensation item which is not an eligible deferred compensation item—

For purposes of this subsection, the term “eligible deferred compensation item” means any deferred compensation item with respect to which—

For purposes of this subsection, the term “deferred compensation item” means—

Paragraphs (1) and (2) shall not apply to any deferred compensation item to the extent attributable to services performed outside the United States while the covered expatriate was not a citizen or resident of the United States.

In the case of any interest in a specified tax deferred account held by a covered expatriate on the day before the expatriation date—

For purposes of paragraph (1), the term “specified tax deferred account” means an individual retirement plan (as defined in section 7701 (a)(37)) other than any arrangement described in subsection (k) or (p) of section 408, a qualified tuition program (as defined in section 529), a Coverdell education savings account (as defined in section 530), a health savings account (as defined in section 223), and an Archer MSA (as defined in section 220).

In the case of a distribution (directly or indirectly) of any property from a nongrantor trust to a covered expatriate—

For purposes of this subsection, the term “taxable portion” means, with respect to any distribution, that portion of the distribution which would be includible in the gross income of the covered expatriate if such expatriate continued to be subject to tax as a citizen or resident of the United States.

For purposes of this subsection, the term “nongrantor trust” means the portion of any trust that the individual is not considered the owner of under subpart E of part I of subchapter J. The determination under the preceding sentence shall be made immediately before the expatriation date.

For purposes of this subsection—

This subsection shall apply to a nongrantor trust only if the covered expatriate was a beneficiary of the trust on the day before the expatriation date.

The term “expatriate” means—

The term “expatriation date” means—

A citizen shall be treated as relinquishing his United States citizenship on the earliest of—

The term “long-term resident” has the meaning given to such term by section 877 (e)(2).

The term “early distribution tax” means any increase in tax imposed under section 72 (t), 220 (e)(4),^[1] 223 (f)(4), 409A (a)(1)(B), 529 (c)(6), or 530 (d)(4).

In the case of any covered expatriate, notwithstanding any other provision of this title—

Solely for purposes of determining any tax imposed by reason of subsection (a), property which was held by an individual on the date the individual first became a resident of the United States (within the meaning of section 7701 (b)) shall be treated as having a basis on such date of not less than the fair market value of such property on such date. The preceding sentence shall not apply if the individual elects not to have such sentence apply. Such an election, once made, shall be irrevocable.

If the expatriation of any individual would result in the recognition of gain under section 684, this section shall be applied after the application of section 684.