### Question
How is the "taxable payment" defined?


### Answer
The term **taxable payment** is defined in *26 U.S.C. § 877A* as follows -

> with respect to a covered expatriate any payment to the extent it would be includible in the gross income of the covered expatriate if such expatriate continued to be subject to tax as a citizen or resident of the United States

#### Citation:
  - *26 U.S.C. § 877A*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART II-NONRESIDENT ALIENS AND FOREIGN CORPORATIONS > Subpart A-Nonresident Alien Individuals**

