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IRC §877A · screening tests

Covered expatriate tests for 2026

By Danilson Ramos · Founder, Atamatax

Tax review partner: onboarding in progress. This article has not yet been independently reviewed by a credentialed professional — every figure cites its IRS source so you can verify it directly.

Direct answer

For a 2026 expatriation, an individual is generally a covered expatriate if any test applies: the five-year average annual net income tax liability is more than $211,000; net worth is $2 million or more on the expatriation date; or the person cannot certify five preceding years of federal tax compliance on Form 8854. Exceptions for certain dual citizens and minors are narrow and still require the certification.

What to know

  • The 2026 indexed liability threshold is more than $211,000.
  • The statutory net-worth threshold is $2 million or more.
  • The certification test can apply regardless of income or net worth.
  • Estimated inputs create a screen, not a determination.

Average annual net income tax liability

The calculation uses the five tax years ending before expatriation and the Form 8854 methodology. For 2026, Rev. Proc. 2025-32 sets the threshold at more than $211,000. The figure is tax liability, not gross income, and the underlying returns need review.

Net worth

The test is met at $2 million or more on the expatriation date. Worldwide assets and liabilities, ownership interests, valuation dates, gifts, and significant recent changes can require professional valuation and tax analysis.

Certification and exceptions

Failure to certify the five-year history is an independent test. Certain dual citizens from birth and certain minors may be excepted from the first two tests when every condition is met, but the Form 8854 certification still matters.

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Questions

Is $211,000 an income threshold?

No. It is the 2026 threshold for the average annual net income tax liability calculated under the applicable rules.

Does being under $2 million settle the question?

No. The tax-liability or certification test may still apply.

Primary sources

Rules checked September 7, 2026. Use the form and instructions for the actual expatriation year.