Tom, a U.S. citizen, expatriated in 2017 and he has since then been a U.S. income tax nonresident alien ("NRA") and a U.S. estate and gift tax nonresident alien domiciliary ("NRAD"). At the time of Tom's expatriation, his net worth was $20 Million. Shortly after expatriating, Tom experienced substantial financial losses and his net worth dropped to $1,500,000 where it remained until he won the Country X jackpot lotto of $100,000,000 in late 2021. Tom then died in early 2022 and his Country X Last Will & Testament left his entire estate to his U.S. citizen son, Michael. Michael will not be subject to any tax on his 2022 inheritance because the lotto winnings took place after Tom had expatriated.

True

False