The United States Internal Revenue Code taxes an individual as either a citizen, resident alien, or nonresident alien. Although citizens and resident aliens are subjected to relatively high tax rates, Congress has given nonresident aliens significant tax advantages designed to encourage foreign investment in the United States. Generally, the nonresident alien is not taxed on any capital gains realized from United States investments, and is subject to only fifteen to thirty percent withholding tax on rents, royalties, interest, and other fixed and periodic items of passive income not effectively connected with the conduct of a trade or business within the United States. 1 Understandably, some citizens may seek nonresident alien status in order to take advantage of these dramatic tax benefits. To achieve this result, the United States citizen must expatriate, that is, he must relinquish both his United States citizenship and residency. Although Congress has enacted legislation which attempts to eliminate the substantial tax benefits resulting from expatriation, careful planning can immunize these anti-expatriation measures. This Note explores the rules regarding taxation of expatriate Americans and considers techniques for eliminating all income taxation of expatriates.