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US Exit Tax

Under the US exit tax, the IRS treats a covered expatriate as having sold everything the day before giving up citizenship or a long-held green card. The IRS calls it the expatriation tax.

A senior CPA reviews your situation in confidence, with a reply in about two hours.

  • $2,000,000. Net worth on the expatriation date at which you become a covered expatriate.

  • $211,000. Average annual net income tax over the five prior years above which you become a covered expatriate (2026).

  • $910,000. Gain excluded from the deemed sale for expatriations in 2026.

Who is a covered expatriate

You are a covered expatriate under IRC section 877A if you meet any one of three tests.

  • Net worth test.

    Your worldwide net worth is $2,000,000 or more on the expatriation date, counting your home, business, retirement accounts and trust interests. The $2,000,000 figure is not adjusted for inflation.

  • Tax liability test.

    Your average annual net income tax for the five years before expatriation exceeds $211,000 for 2026, under Rev. Proc. 2025-32.

  • Certification test.

    You cannot certify on Form 8854, under penalty of perjury, that you met every federal tax obligation for the five prior years. One unfiled return in those years is enough to fail.

Green card exit tax

Green card holders pay the exit tax only as long-term residents. A long-term resident held the card in at least 8 of the 15 tax years ending with the year they give it up. A card held since 2018 is long-term in 2026. A long-term resident who claims treaty benefits as a resident of another country is treated as having ended US residency.

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Covered expatriate exceptions

Two groups avoid the net worth and tax liability tests if they pass the certification test:

  • A dual citizen from birth who remains a citizen and tax resident of the other country, with no more than 10 US resident years in the last 15
  • A person who gives up citizenship before age 18 and a half, after no more than 10 years as a US resident

How the exit tax is calculated

  • Value your assets at fair market value on the day before expatriation, and subtract each one's basis.
  • Add the gains and losses.
  • Subtract the exclusion for the year, allocated across the assets in proportion to their gains.
  • Tax the remainder as if you sold the assets: 0%, 15% or 20% on long-term gains, plus the 3.8% net investment income tax. Short-term gains and collectibles are taxed at their own rates.

Four types of asset have their own rules and no deemed sale.

AssetTreatment at expatriation
Eligible deferred compensation (a US employer's 401(k) or pension)No deemed sale; the payer withholds 30% of each later distribution after you file Form W-8CE
Ineligible deferred compensation (such as a foreign pension)Present value taxed as received the day before expatriation
Specified tax deferred accounts (IRA, HSA, 529)Treated as fully distributed the day before expatriation, with no early withdrawal penalty
Interest in a nongrantor trustNo deemed sale; the trustee withholds 30% of the taxable part of each distribution

A covered expatriate can elect to defer the tax on a deemed gain until the asset is sold, by posting security the IRS accepts and paying interest. The election is irrevocable per asset.

Worked example: a $6,000,000 portfolio

Illustrative: one unmarried covered expatriate in 2026 with no other income or deductions, all gains long-term, no state tax, no deferral election. Brackets from Rev. Proc. 2025-32; the IRS charges the net investment income tax on modified adjusted gross income over $200,000.

ItemAmount
Brokerage account: value $6,000,000, basis $2,500,000Deemed gain $3,500,000
Less the 2026 exclusion$910,000
Taxable deemed gain$2,590,000
First $49,450 at 0%$0
Next $496,050 at 15%$74,407.50
Remaining $2,044,500 at 20%$408,900
Net investment income tax: 3.8% of $2,390,000$90,820
Federal tax$574,127.50

You can lower the tax with gifts, sales, basis step-ups and the timing of the final return. We model the options before anything is filed.

Exit tax planning before you expatriate

  • Fall under the thresholds.

    You can cut net worth below $2,000,000 with gifts before expatriating. Gifts to a US citizen spouse are unlimited; for others you use the $19,000 annual exclusion (2026) and your lifetime exemption.

  • Realize gains early.

    If you sell appreciated assets in the years before you expatriate, you spread the gain over several returns and lower brackets.

  • Fix the five years first.

    Through the IRS Streamlined Filing Compliance Procedures or amended returns, you can certify five years of compliance. If your net worth and average tax are also under the limits, you leave as a non-covered expatriate.

  • Choose the expatriation date.

    The IRS raises the exclusion and the tax liability threshold for inflation each year. If you expatriate early in the year, a shorter part of that year is taxed as a US person.

  • Plan gifts to family in the US.

    After you expatriate, your gifts and bequests to US persons over $19,000 a year (2026) are taxed to the recipient under IRC section 2801, at the top estate tax rate.

Steps to plan your expatriation taxes

  1. Send your documents.

    Your last five returns, a list of assets with cost basis, and any pension or trust statements, through the secure portal.

  2. Run the tests.

    A CPA checks all three covered expatriate tests and lists any missing filings.

  3. Model the deemed sale.

    We value each asset, calculate the US exit tax and compare the planning options.

  4. File.

    We prepare the final return and Form 8854 for the expatriation year.

Factors in exit tax planning fees

We quote after a short review, based on:

  • The number of assets that need a valuation
  • Pensions, deferred compensation or trust interests
  • Years that need catch-up filings
  • Whether you make the deferral election and post security
  • Gifts or sales planned before the expatriation date

The light end is a non-covered expatriate with five compliant years and one brokerage account. These are the factors, not a quote.

Form 8854 and the final return

Every expatriate files Form 8854 with the final return for the expatriation year, whether covered or not. The IRS can impose a $10,000 penalty when a required form is missing. On the form you certify five years of compliance and report your net worth and the deemed sale.

Get the US exit tax calculated before you renounce

Send your last five returns, and a CPA tells you whether you are covered and what the deemed sale would cost.