Skip to content
ChatProjectCodes

Introduction

Part III. Administrative, Procedural, and Miscellaneous

Internal Revenue Bulletin 2009-45 · 2026-10-03 edition · updated 2026-10-04 · United States

Guidance for Expatriates Under Section 877A

Notice 2009–85

PURPOSE

Section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008 (the “Act”) added new sections 877A and 2801 to the Internal Revenue Code (“Code”), amended sections 6039G and 7701(a), made conforming amendments to sections 877(e) and 7701(b), and repealed section 7701(n) with respect to individuals who on or after June 17, 2008, relinquish U.S. citizenship or cease to be lawful permanent residents of the United States. This notice provides guidance for individuals who are subject to section 877A. This notice does not provide new guidance regarding section 877, which continues to apply to individuals who relinquished U.S. citizenship or ceased to be lawful permanent residents prior to June 17, 2008. Additionally, this notice does not address new section 2801, which imposes transfer tax on U.S. persons who receive gifts or bequests on or after June 17, 2008, from individuals who are subject to section 877A (but see section 9 of this notice).

Get a plain-English answer with a citation back to this text.

Ask AI about this code
Export this section
▸Contents — Internal Revenue Bulletin 2009-45
Internal Revenue Bulletin 2009-45

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.