Expatriate

Expatriate means:
a nonresident alien who lost U.S. citizenship within the 10-year period preceding the close of the tax year and had as one of his or her principal purposes the avoidance of taxes. Persons who have left their country and live abroad. The expatriate is still subject to U.S. taxation as a nonresident alien or at a special “alternative tax” rate, whichever is higher. Former IRC (check if this IRC provision is current here) §877.

Expatriate Rules in the U.S. and other Developed Countries International Tax Meaning

Rules under which a taxpayer continues to be subject to tax when he relinquishes his residence or his citizenship in order to avoid tax.