They are Australia and Canada. But they are different than ours. As an example. they would allow a stepup in basis. so if you were to go. for example. from Hong Kong to Canada and then emigrate from Canada somewhere else. you would get the stepup in basis. so the gain would only be during the time in which you are a resident or a citizen of Canada. That is a big difference from our proposal that we have before us which would not allow that stepup in basis. Second. those two countries allow a deferral. so you can allow a deferral in the payment of the gain until the asset is actually sold.
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emigrate