items of income, gain, deduction, and loss which are effectively connected with the conduct of trades or businesses within the United States. (B) Asset test For purposes of the asset test under subsection (a)(3)— (i) such subsection shall be applied for purposes of this subparagraph by substituting $500,000,000 for the dollar amount otherwise in effect for such taxable year under such paragraph, and (ii) only assets which produce income described in subparagraph (A) shall be taken into account. (2) Expatriates (A) In general If, for the taxable year which includes a covered expatriate's expatriation date, such expatriate— (i) was an applicable taxpayer (without regard to this paragraph), or (ii) is an applicable taxpayer under the rules of subparagraph (B), such expatriate shall be treated as an applicable taxpayer during each of the taxable years during the 10-taxable-year period beginning with such taxable year (and such status shall not be terminated during such period by reason of any other provision of this part). (B) Special rules for determining status For purposes of subparagraph (A)(ii), a covered expatriate not otherwise treated as an applicable taxpayer shall be treated as an applicable taxpayer if, during any of the 5 taxable years immediately preceding the taxable year which includes the covered expatriate's expatriation date (including taxable years beginning before the date of the enactment of this part which are included in any such 5-taxable year period), the expatriate meets either— (i) the income test of subsection (a)(2), except that such subsection shall be applied for purposes of this subparagraph by substituting $50,000,000 for the dollar amount otherwise in effect for such taxable year under such paragraph, or (ii) the asset test of subsection (a)(3), except that such subsection shall be applied for purposes of this subparagraph by substituting $500,000,000 for the dollar amount otherwise in effect for such taxable year under such paragraph. (C) Definitions Any term used in this paragraph