@taoj , your understanding is correct.
This code section 877-A and the special rule also does not include even those persons whom have passed Substantial Presence Test and are taxed as Resident for Tax purposes ,
This section hints at and is probably applicable also to Long-Term Residents whom have been subject to Mark-to-Market rules when leaving the country and then come back -- I need to study the rule a little bit more extensively for that portion of the rules
Is there more I can do for you ?
