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Mark is a U . S . citizen who has lived in the United States since birth. He owns stock with a fair market value

Mark is a U.S. citizen who has lived in the United States since birth. He owns stock with a fair market value of $3 million. His basis in the stock is $500,000. Mark decides to relinquish his U.S. citizenship to move to Singapore. What are the U.S. tax consequences of this action?
a. Mark will be subject to U.S. taxes on his built-in gain, and he will be required to remit payment to the U.S. government before he can exit the country.
b. Mark will not qualify as a covered expatriate because there is an exception for stock. He will not have any U.S. tax liability.
c. Mark will not qualify as a covered expatriate and be subject to the mark-to-market tax regime upon expatriation.
d. Mark will not qualify as a covered expatriate because the value of his stock is below the required threshold. He will not have any U.S. tax liability.

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