I'm dealing with a very tricky situation. My client expatriated (gave up citizenship) from the United States a while back. Because they expatriated during a certain year, they are subject to a special rule and will be subject to US tax on their worldwide income for any of the 10 years following expatriation in which they are present in the US for more than 30 days (in this particular case). The client would like to return to the US for some business this coming year. I'm trying to do a calculation on the potential tax effects but I'm not sure whether the foreign income tax credit or the income tax exclusion would apply to an expatriated individual (in this case expatriated meaning no longer a citizen).