 However, former IRS lawyers, as well as the Department of Homeland Security, have indicated that the provision is unenforceable because there is no authority for the IRS to share tax return information to enforce it.DHS stated that they can only enforce the Reed Amendment when former US citizens "affirmatively admit to renouncing their U.S. citizenship for the purpose of avoiding U.S. taxation", and between 2002 and 2015 they denied entry to only two former US citizens on the basis of the amendment.In 2008, Congress enacted the Heroes Earnings Assistance and Relief Act, which changed the expatriation tax to a one-time mark-to-market worldwide capital gains tax rather than ten years of taxation on US-source income.