Treatment of covered expatriates

(a) Application of expatriate rules to applicable taxpayers Section 877A is amended by redesignating subsection (i) as subsection (j) and by inserting after subsection (h) the following new subsection: (i) Special rules for applicable taxpayers (1) In general In the case of a covered expatriate who is an applicable taxpayer (as defined in section 495) for the taxable year which includes the expatriation date— (A) no election may be made under subsection (b) with respect to any property treated as sold by reason of subsection (a) (after application of subparagraph (B)), and (B) the covered expatriate shall, for purposes of subsection (a)(1), also be treated as having sold on the last day of the 10-taxable-year period described in section 495(d)(2)(A) all property held by the covered expatriate as of the close of such day which is not otherwise treated as sold under part IV of subchapter E as of such time. (2) Application of section 877 Notwithstanding section 877(h)— (A) a covered expatriate described in paragraph (1) shall be treated as an individual to whom section 877 applies, and (B) such individual shall be taxable as provided in such section for each of the taxable years in the 10-taxable-year period described in section 495(d)(2)(A).. (b) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2025.