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On June 17, 2008, under section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008, Congress created a new chapter 15 of the Internal Revenue Code and added section 2801. This new provision imposes a tax on a U.S. citizen or resident receiving a covered gift or covered bequest during the calendar year. A covered gift or covered bequest is a gift or bequest received from a covered expatriate, with certain exceptions. The tax is calculated by multiplying the value of the total covered gifts and covered bequests received during the year, reduced by the section 2503(b) amount, by the highest estate tax rate (or gift tax rate if higher) for the taxable year. On July 20, 2009, the Treasury Department and the IRS issued Announcement 2009-57, which states that the Treasury Department and the IRS intend to issue guidance under section 2801 and new Form 708. Proposed regulations were issued on September 10, 2015. The final regulations will provide guidance on the tax imposed by section 2801 on U.S. citizens and residents and certain individuals who relinquished U.S. citizenship or ceased to be lawful permanent residents of the U.S. on or after June 17, 2008, and will provide guidance on new Form 708, including the due date for filling and paying the section 2801 tax.