The U.S. IRS has published a practice unit, Expatriation On or After June 17, 2008 – Mark-to-Market (MTM) Tax Regime. The general overview of the practice unit includes the following:
This unit discusses the Mark-to-Market (MTM) rules under IRC 877A, which imposes an "exit tax" through a MTM tax regime on the worldwide assets of a "covered expatriate" (CE).
An expatriate means (1) a U.S. citizen who relinquishes their citizenship, or (2) a long-term resident of the United States who cease…