A previous post explained why lawful permanent residents (LPRs) can never satisfy this exception in the law to avoid “covered expatriate status.” See, Why a “long-term” LPR can NEVER avoid “Covered Expatriate” status under IRC Section 877A(g)(1)(B) if Asset or Tax Liability Test is Satisfied!
For the same reasons, a naturalized citizen cannot satisfy the statutory requirement since they will never be able to meet the IRC Section 877A(g)(1)(B)(i)(I) requirement of becoming ” . . . at birth a citizen of the United States . . . ”
Of course a naturalized United States citizen by definition was not a citizen at birth and only became one upon completing the lengthy legal requirements of naturalization. See, USCIS website – Citizenship Through Naturalization
Posted on May 19, 2014