12 2 STA T . 1 639PUBLIC LA W 11 0– 2 45—J U NE 1 7, 200 8‘ ‘ (A)INGE NE RAL.—Theamountw h ic h wou ld ( b ut f o r thi sp ara g raph) be includible in the gross income of an y indi v idual by reason of paragraph ( 1 ) shall be reduced (but not below z ero) by $60 0 , 000. ‘‘( B )A DJUSTM ENT FO R I NFLATION.— ‘‘(i) IN GENERAL.—In the case of any ta x able year beginning in a calendar year after 2 00 8 , the dollar amount in subparagraph (A) shall be increased by an amount e q ual to— ‘‘(I) such dollar amount, multiplied by ‘‘(II) the cost - of-living ad j ustment determined under section 1(f)( 3 ) for the calendar year in which the taxable year begins, by substituting ‘calendar year 200 7’ for ‘calendar year 1 9 92’ in subparagraph (B) thereof. ‘‘(ii) R OUNDING.—If any amount as adjusted under clause (i) is not a multiple of $1,000, such amount shall be rounded to the nearest multiple of $1,000. ‘‘(b) E LE C TION TO D EFER TA X .— ‘‘(1) IN GENERAL.—If the taxpayer elects the application of this subsection with respect to any property treated as sold by reason of subsection (a), the time for payment of the addi- tional tax attributable to such property shall be extended until the due date of the return for the taxable year in which such property is disposed of (or, in the case of property disposed of in a transaction in which gain is not recognized in whole or in part, until such other date as the S ecretary may prescribe). ‘‘(2) DETERMINATION OF TAX W IT H RES P ECT TO PROPERT Y .— F or purposes of paragraph (1), the additional tax attributable to any property is an amount which bears the same ratio to the additional tax imposed by this chapter for the taxable year solely by reason of subsection (a) as the gain ta k en into account under subsection (a) with respect to such property bears to the total gain taken into account under subsection (a) with respect to all property to which subsection (a) applies. ‘‘(3) TERMINATION OF EXTENSION.—The due date for pay- ment of tax may not be extended under this subsection later than the due date for the return of tax imposed by this chapter for the taxable year which includes the date of death of the expatriate (or, if earlier, the time that the security provided with respect to the property fails to meet the requirements of paragraph ( 4 ), unless the taxpayer corrects such failure within the time specified by the Secretary). ‘‘(4) SECURITY.— ‘‘(A) IN GENERAL.— N o election may be made under paragraph (1) with respect to any property unless adequate security is provided with respect to such property. ‘‘(B) ADE Q UATE SECURITY.—For purposes of subpara- graph (A), security with respect to any property shall be treated as adequate security if— ‘‘(i) it is a bond which is furnished to, and accepted by, the Secretary, which is conditioned on the payment of tax (and interest thereon), and which meets the requirements of section 632 5 ,or ‘‘(ii) it is another form of security for such payment (including letters of credit) that meets such require- ments as the Secretary may prescribe.
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