CONTENTS Executive Summary I. Summary of Current Law A. General Provisions B. Foreign Earned Income Exclusion and Foreign Tax Credit (Code Sections 911 and 901) C. Expatriation to Avoid Tax (Code Section 877) II. Compliance Measurement and Improvement A. Demographic Study of Overseas Compliance B. Efforts to Improve Compliance C. Factors Limiting Efforts to Measure and Improve Compliance III. Sharing of Information Between Agencies A. Information from Department of State Regarding U.S. Citizens and Former U.S. Citizens Living Abroad 1. Individuals Who Retain Citizenship a. Passport Data (Code Section 6039E) b. Department of State Restrictions on Additional Information 2. Individuals Who Lose Citizenship (Code Section 6039G) B. Information from INS Regarding Lawful Permanent Residents Living Abroad 1. Individuals Who Retain Green Card a. Green Card Data (Code Section 6039E) b. INS Databases 2. Green Card Holders Whose Status is Revoked/Determined to Be Abandoned IV. Definition of Individuals Subject to U.S. Taxation A. Definition of U.S. Citizen for Tax Purposes 1. Modification of Nationality Law Definition 2. Modification of Tax Law Definition a. Elimination of Retroactive Effect of Citizenship Loss b. Relief for "Unknowing" or "Restored" Citizens B. Definition of Lawful Permanent Resident Subject to Tax V. Conclusion and Recommendation