covered expatriate
(A)The term “covered expatriate” means an expatriate who meets the requirements of subparagraph (A), (B), or (C) of section 877(a)(2). (B)An individual shall not be treated as meeting the requirements of subparagraph (A) or (B) ofif— (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) 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 (C)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.