SECTION 2. INDIVIDUALS

COVERED

A. Definitions

Expatriate . Section 877A(g)(2) provides that the term “expatriate” means (1) any U.S. citizen who relinquishes his

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(1) commences to be treated as a resident of a foreign country under the provisions of a tax treaty between the United States and the foreign country, (2) does not waive the benefits of the treaty applicable to residents of the foreign country, and (3) notifies the Secretary of such treatment on Forms 8833 and 8854.

B. Tax Liability and Net Worth Tests

For guidance on determining whether an individual is a covered expatriate by reason of the tax liability test or the net worth test, see Section III of Notice 97–19, 1997–1 C.B. 394.