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Expatriate Rules in HEART Act of 2008 Affect Deferred Compensation
Deloitte via BenefitsLink 
[Guidance Overview] July 3, 2008
Excerpt: Expatriation on or after June 17, 2008, may cause an expatriate to be subject to IRC § 877A, which was enacted as part of the Heroes Earnings Assistance and Relief Tax Act (HEART) Act of 2008.... If a deferred compensation item is not an eligible deferred compensation item (and not subject to IRC § 83), an amount equal to the present value of the deferred compensation item is treated as having been received on the day before the expatriation date.
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