This bill would allow U.S. citizens living abroad to voluntarily switch to a residency-based tax system instead of the current citizenship-based system, meaning they would only owe taxes to the United States on income earned while residing in the country, not worldwide income. To elect this option, citizens must meet IRS requirements, including paying a one-time tax on the appreciation of their worldwide assets as of the election date, though certain property like retirement accounts, U.S. real estate, and principal residences abroad are exempt from this immediate tax. The bill includes a provision allowing citizens to defer payment of taxes on non-readily tradable property until they actually sell it, provided they post adequate security. Additionally, the legislation would require foreign financial institutions to stop discriminating against U.S. citizens who are residents of their countries and would establish a system for issuing nonresidency certificates with a $100 application fee, adjusted annually for inflation.