The expatriation tax provisions under Section 877 and Section 877A of the Internal Revenue Code (IRC) apply to U.S. citizens who give up their citizenship, and long-term residents who end their U.S. resident status for federal tax purposes. The expatriation tax in the U.S. is based on the value of an individual taxpayer’s property on the day before their expatriation. These come into effect when you either renounce your US citizenship or terminate your status as a US resident (GCH) for tax purposes.