Covered Gifts & IRC 2801 Covered Gifts & IRC 2801: When a person is a covered expatriate, the US tax rules can follow them for many years after they renounced or relinquished their U.S. Citizenship or Permanent Resident Status. The IRS post-expatriation tax consequences of being a covered expatriate become most apparent when a covered … Continue reading Covered Gifts & IRC 2801 Expatriate Gift Tax