Nonresident alien individuals who lost U.S. citizenship within a 10-year period immediately preceding the close of the tax year must pay taxes on their U.S.-source income as though they were still U.S. citizens. This provision applies only if the expatriation had as one of its principal purposes the avoidance of U.S. taxes. Individuals are presumed to have a tax avoidance purpose if they meet either of the following criteria:

Average annual net income tax for the five taxable years ending before the date of loss of U.S. citizenship is more than $___________ in 2020.