taxable portion

(2) Taxable portion 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.


26 USC § 877A(f)(2)

Scoping language

For purposes of this subsection
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