110 STAT. 2094
PUBLIC LAW 104-191—AUG. 21, 1996
"(1) IN GENERAL.—Subsection (a)(2) shall not apply to an
individual if—
"(A) such individual is described in a subparagraph
of paragraph (2) of this subsection, and
"(B) within the 1-year period beginning on the date
of the loss of United States citizenship, such individual
submits a ruling request for the Secretary's determination
as to whether such loss has for one of its principal purposes
the avoidance of taxes under this subtitle or subtitle B.
"(2) INDIVIDUALS DESCRIBED. —
"(A) DUAL CITIZENSHIP, ETC.— An individual is
described in this subparagraph if—
"(i) the individual became at birth a citizen
of the United States and a citizen of another country
and continues to be a citizen of such other country,
or
"(ii) the individual becomes (not later than the
close of a reasonable period after loss of United States
citizenship) a citizen of the country in which—
"(I) such individual was born,
"(II) if such individual is married, such individual's spouse was born, or
"(III) either of such individual's parents were
born.
"(B) LONG-TERM FOREIGN RESIDENTS.—An individual
is described in this subparagraph if, for each year in the
10-year period ending on the date of loss of United States
citizenship, the individual was present in the United States
for 30 days or less. The rule of section 7701(b)(3)(D)(ii)
shall apply for purposes of this subparagraph.
" (C) RENUNCIATION UPON REACHING AGE OF MAJOR-
ITY. — An individual is described in this subparagraph if
the individual's loss of United States citizenship occurs
before such individual attains age I8V2.
"(D) INDIVIDUALS SPECIFIED IN REGULATIONS. — An
individual is described in this subparagraph if the individual is described in a category of individuals prescribed
by regulation by the Secretary.".
(2) TECHNICAL AMENDMENT.— Paragraph (1) of section
877(b) of such Code is amended by striking "subsection (c)"
and inserting "subsection (d)".
(c) TREATMENT OF PROPERTY DISPOSED OF IN NONRECOGNITION
TRANSACTIONS; TREATMENT OF DISTRIBUTIONS FROM CERTAIN CON-
TROLLED FOREIGN CORPORATIONS.— Subsection (d) of section 877,
as redesignated by subsection (b), is amended to read as follows:
"(d) SPECIAL RULES FOR SOURCE, ETC. — For purposes of subsection (b)—
"(1) SOURCE RULES.—The following items of gross income
shall be treated as income from sources within the United
States:
"(A) SALE OF PROPERTY. —Gains on the sale or exchange
of property (other than stock or debt obligations) located
in the United States.
"(B) STOCK OR DEBT OBLIGATIONS.— Gains on the sale
or exchange of stock issued by a domestic corporation or
debt obligations of United States persons or of the United
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