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This bill would allow U.S. citizens living abroad to elect residency-based taxation instead of the current citizenship-based system. Under the election, qualifying Americans abroad would be taxed only on U.S.-source income and foreign-source income earned while a U.S. resident, similar to foreign nationals. The bill requires high-net-worth individuals (exceeding the estate tax exemption threshold) to recognize gains on their worldwide assets as of the election date, though certain property types and retirement accounts are excluded. Elections are irrevocable but terminate if the individual becomes a U.S. resident.
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