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Amends the Internal Revenue Code to establish that all property of "covered expatriates" shall be treated as sold on the day before the "expatriation date" for its fair market value, and that gain and loss shall be taken into account for the taxable year of the sale (with proper subsequent adjustment). Defines "expatriate" and "expatriation date."Permits an individual to make an irrevocable decision to defer the additional tax attributable to such property provided that adequate security is furnished and that the individual waives any rights under treaties of the United States that would preclude assessment or collection of relevant tax.Excludes certain "United States real property interests" and interest in certain retirement plans from counting as sold under this Act. Establishes special rules applicable to "covered expatriates'" interests in trusts and qualified trusts, including a tax in instances of the latter. Sets forth that such tax shall be replaced by another tax under certain delineated conditions, including if a trust ceases to be a qualified trust.Imposes a tax on "covered gifts and bequests" of more than $10,000 from expatriates to American citizens and residents, with certain specified exceptions.

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