covered expatriate
(1) Covered expatriate (A) In general The term “covered expatriate” means an expatriate who meets the requirements of subparagraph (A), (B), or (C) of section 877(a)(2). (B) Exceptions An individual shall not be treated as meeting the requirements of subparagraph (A) or (B) of section 877(a)(2) if— (i) the individual— (I) became at birth a citizen of the United States and a citizen of another country and, as of the expatriation date, continues to be a citizen of, and is taxed as a resident of, such other country, and (II) has been a resident of the United States (as defined in section 7701(b)(1)(A)(ii) ) for not more than 10 taxable years during the 15-taxable year period ending with the taxable year during which the expatriation date occurs, or (ii) (I) the individual’s relinquishment of United States citizenship occurs before such individual attains age 18½, and (II) the individual has been a resident of the United States (as so defined) for not more than 10 taxable years before the date of relinquishment. (C) Covered expatriates also subject to tax as citizens or residents In the case of any covered expatriate who is subject to tax as a citizen or resident of the United States for any period beginning after the expatriation date, such individual shall not be treated as a covered expatriate during such period for purposes of subsections (d)(1) and (f) and section 2801.