To amend the Internal Revenue Code of 1986 to prevent the continued use of renouncing United States citizenship as a device for avoiding United States taxes.

This bill, introduced in 2002, proposes to change how the U.S. government taxes individuals who renounce their citizenship or long-term residency. Under this legislation, "covered expatriates" would be treated as if they sold all of their global assets for fair market value the day before leaving the country, making any capital gains on those assets immediately subject to U.S. income tax.

For the average citizen, this bill aims to ensure that wealthy individuals cannot avoid paying taxes on wealth accumulated while living in the U.S. by moving abroad. While it includes provisions to defer tax payments under certain conditions and exempts specific retirement accounts, it also introduces a new tax on large gifts or inheritances sent back to U.S. citizens from those who have renounced their citizenship.