XVI.   Expatriation Provisions "Exit Tax"

Individuals who relinquish U.S. citizenship are subject to special tax provisions for 10 years. U.S. source income as well as foreign income derived from the exchange of U.S.-source property to foreign-source property and expatriation property are subject to tax at the rates that apply to U.S. citizens. This applies not only to U.S. citizens but also to long term residents (lawful permanent resident of the U.S. for at least 8 of the 15 tax years ending with the year residency terminates).