Expatriation
Giving up U.S. citizenship or a long-held green card: Form 8854, the exit tax, and covered-expatriate rules.
- 01→The exit tax for covered expatriatesIf you trip any of the three covered-expatriate tests, IRC §877A deems your worldwide assets sold the day before expatriation. Here's the mark-to-market math, the deferral election, the deferred-comp rules, and the §2801 tail on gifts to U.S. recipients.11 min read
8854W-8CE1040 - 02→Giving up U.S. citizenship: the tax sideRenouncing U.S. citizenship — or formally abandoning a long-held green card — triggers a U.S. tax exit process. Here's how the covered-expatriate tests work in 2025, the two exceptions that protect dual citizens and minors, and the obligations that don't end at the embassy door.11 min read
8854W-8CE1040