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Internal Revenue Bulletin:  2009-45 

November 9, 2009 


Notice 2009-85 Notice 2009-85

This notice provides guidance under section 877A of the Code, which was enacted by section 301 of the Heroes Earnings Assistance and Relief Act of 2008 (the “Act”) and applies to individuals who expatriate on or after June 17, 2008. Section 877A generally provides that all property of a “covered expatriate” is treated as sold on the day before the individual’s expatriation date. Gain and loss from the deemed sale must be taken into account at that time (subject to a $600,000 exclusion amount, which will be indexed for inflation) unless the individual elects to defer payment of the tax by providing security and waiving treaty rights that would prevent assessment or collection of the deferred tax. There are special rules for deferred compensation items, specified tax deferred accounts, and interests in nongrantor trusts.

Rev. Proc. 2009-50 Rev. Proc. 2009-50

Cost-of-living adjustments for 2010. This procedure sets forth the cost-of-living adjustments to certain items for 2010 due to inflation as required under various provisions of the Code and Service guidance.

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