Skip to main content

Topic · US expats

US Exit Tax & Form 8854: Renouncing Citizenship or Giving Up a Green Card

How the covered-expatriate screens, 2026 thresholds, special-asset rules, filing timing, and five-year certification fit together.

By Danilson Ramos · Founder, Atamatax

Published June 2026 · Updated October 2026

Reviewed and approved by our EA/CPA team on .

Direct answer

Who is a covered expatriate for the US exit tax?

For a 2026 expatriation, a person who renounces citizenship or ends long-term green-card residence is a covered expatriate if any one test applies: average annual net income tax liability over the prior five years of more than $211,000; net worth of $2,000,000 or more; or failure to certify 5 years of federal tax compliance on Form 8854.

A covered expatriate is taxed as if their worldwide property were sold the day before expatriation, with the first $910,000 of gain excluded for 2026; deferred compensation, specified tax-deferred accounts and non-grantor trusts follow separate rules.

Applies when
US citizens who renounce or relinquish citizenship, and long-term residents — a green card held in at least 8 of the last 15 years — who give it up.
Underlying rule
IRC §877A and §877(a)(2); the income-tax threshold is indexed each year (Rev. Proc. 2025-32 for 2026), the net-worth test is not.
Important exception
Narrow exceptions for certain dual citizens from birth and for some who expatriate before age 18½ remove the financial tests — not the five-year certification.
What remains uncertain
Net worth is valued on the expatriation date and the liability figure comes from the actual returns; an estimate is a screen, not a determination.
Last verified

What changes the answer

  • One of the five preceding years is not filed or not compliant: the certification test can make you covered whatever your income or net worth.
  • The expatriation date moves into another calendar year: that year's indexed thresholds apply.
  • You hold deferred compensation, a foreign pension or a non-grantor trust interest: those items follow their own rules outside the mark-to-market computation.

Next step: Check my renunciation readiness

Form 8854 is the IRS initial and, for certain ongoing items, annual expatriation statement. It is part of the federal tax process; the Department of State separately administers loss of nationality. This page explains tax readiness; whether to renounce is your decision, administered by the Department of State.

Are you a 'covered expatriate'?

The exit tax generally applies only to covered expatriates — those who meet any one of these tests at expatriation:

TestBroad triggerNotes
Net worthNet worth at or above $2 millionNot inflation-indexed in the same way as the tax test; values most worldwide assets
Average tax liabilityFor 2026, average annual net income tax liability over the prior 5 years is more than $211,000The threshold is indexed; use the rule for the actual expatriation year
CertificationFailure to certify 5 years of U.S. tax compliance on Form 8854Applies even if you're below the net worth and tax thresholds
The certification test is independent: an expatriate who cannot certify the five preceding years can be a covered expatriate even when neither financial test is indicated. The certification is yours to make from the five years' records.

Limited exceptions to covered-expatriate status

Some narrow exceptions exist — for example, certain dual citizens from birth who continue to meet specific conditions, and certain individuals who expatriate before a defined age — may avoid covered-expatriate status even if they cross the net worth or tax thresholds. Crucially, these exceptions generally still require meeting the five-year certification, and their conditions are precise, so they should be confirmed rather than assumed.

The mark-to-market exit tax

For covered expatriates, the exit tax generally works on a mark-to-market basis: most worldwide assets are treated as if sold at fair market value the day before expatriation. For 2026, net gain otherwise included is reduced, but not below zero, by $910,000. Eligible and ineligible deferred compensation, specified tax-deferred accounts, and nongrantor trusts follow separate rules rather than the general deemed-sale computation.

Form 8854 and the compliance requirement

  • Form 8854 is the official expatriation statement; without filing it, you can be treated as a covered expatriate.
  • You generally must be able to certify five years of U.S. tax compliance.
  • Renouncing does not erase prior obligations — back filings may still need to be addressed first.

A rough sequence to think about

  1. Get five prior years compliant (returns plus any FBAR/Form 8621/other forms you missed), since certification depends on it.
  2. Estimate covered-expatriate exposure — run the net worth and average-tax tests for your situation.
  3. Model the mark-to-market computation and the special regimes for pensions and deferred items.
  4. File Form 8854 for the expatriation year and complete the consular/USCIS expatriation step as applicable.
Expatriation is irreversible and the interactions (gift/inheritance consequences for U.S. recipients of a covered expatriate, deferred-compensation withholding, trust rules) are intricate. This page is general information; an expatriation decision warrants individualized professional advice.

Build the five-year record before choosing a service

The free Expatriation Tax Readiness check separates filed, prepared, reviewed, missing, and not-required items, then routes the case for professional review where needed.

Authorities cited

  • IRC §877A — IRC §877A — Tax responsibilities of expatriation (mark-to-market exit tax)
  • IRS Form 8854 — About Form 8854 — Initial and Annual Expatriation Statement
  • IRS annual inflation adjustments — IRS annual inflation adjustments (Rev. Proc.) — indexed limits/thresholds; verify per tax year
  • FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
  • IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF

Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.

Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.

Frequently asked questions

Will I definitely owe an exit tax if I renounce?#
Not necessarily. The exit tax generally applies only to 'covered expatriates' who meet the net worth, average tax liability, or certification tests. Many people who are fully tax-compliant and below the thresholds aren't subject to it — but the analysis is fact-specific.
Why do I have to be tax-compliant before renouncing?#
Form 8854 requires certifying five years of U.S. tax compliance. If you can't, you can be treated as a covered expatriate regardless of your net worth or income, so getting compliant first is generally the starting point.
Does giving up a green card count too?#
Yes, it can. Long-term green card holders (generally those who held it for a sufficient number of years) can be subject to the same expatriation rules and Form 8854 when they give it up. Because this is fact-specific and significant, professional guidance is warranted.

Related guides

Preparation · price before you start

If you want the missing years prepared

Which route fits depends on a few facts, not on the balances. These are the common situations and the route the same rules give each one. Nothing is charged until you generate a package or accept a written quote.

  1. Several years unfiled; wages, pensions and bank accounts, no non-US funds

    Streamlined Essential · $1,590 · Done-with-you case preparation, scoped first

    Wages, pensions or bank accounts with no non-US funds is the standard catch-up scope: three returns, six FBARs, and the certification package.

    What arrives, who prepares and checks it, and who files

    A Streamlined Foreign Offshore preparation package: up to three delinquent returns and six FBAR years as worksheets mapped to each year's official forms (official pre-filled PDFs only for tax year 2025), a document completeness check, the Form 14653 organiser, and filing instructions — one scoped quote, one payment.

    A CPA or Enrolled Agent from the Atamatax team, assigned according to your case (its forms, countries and complexity), prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures, and signs as paid preparer. They are named on your case once they accept. If no professional has been assigned 7 days after payment, you choose between waiting and a full refund. You write your own statement of facts.

    The CPA or Enrolled Agent assigned to your case reviews and answers for the work they sign; a person at Atamatax checks the file is complete before it reaches you.

    You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Get a scoped quote
  2. The same, with non-US funds or a personal foreign pension

    Streamlined Investor · $2,200 · Done-with-you case preparation, scoped first

    The catch-up years include non-US funds or a personal foreign plan, so each back year needs PFIC work as well as the return and the FBAR.

    What arrives, who prepares and checks it, and who files

    A CPA or Enrolled Agent from the Atamatax team, assigned according to your case (its forms, countries and complexity), prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures, and signs as paid preparer. They are named on your case once they accept. If no professional has been assigned 7 days after payment, you choose between waiting and a full refund. You write your own statement of facts.

    The CPA or Enrolled Agent assigned to your case reviews and answers for the work they sign; a person at Atamatax checks the file is complete before it reaches you.

    You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Get a scoped quote
  3. The same, with a foreign company, a trust, or more than ten funds

    Streamlined Complex · From $2,990 · Done-with-you case preparation, scoped first

    Several unfiled years plus a foreign company, a trust or a large fund portfolio is the hand-scoped tier: the scope is set before any price is quoted, and a company or trust return is prepared by a specialist alongside the personal returns.

    What arrives, who prepares and checks it, and who files

    A CPA or Enrolled Agent from the Atamatax team, assigned according to your case (its forms, countries and complexity), prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures, and signs as paid preparer. They are named on your case once they accept. If no professional has been assigned 7 days after payment, you choose between waiting and a full refund. You write your own statement of facts.

    The CPA or Enrolled Agent assigned to your case reviews and answers for the work they sign; a person at Atamatax checks the file is complete before it reaches you.

    You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Get a scoped quote
  4. An IRS examination is open, or willfulness is an open question

    Confirm the scope before choosing a package · Free to ask

    The IRS has already been in contact. The published catch-up routes close once an examination is open, so the next step is a conversation about representation, not a filing package.

    What arrives, who prepares and checks it, and who files

    Free to ask. A person reads the facts and says whether Atamatax can take the case, and which route it would be.

    A person at Atamatax reads the facts before any route is offered.

    See whether Atamatax can take the case

When a professional's judgment is needed. An open IRS examination, a question about whether the missed years were willful, or an unsettled US status goes to a person before anything is quoted — those decide whether a catch-up procedure is available at all, and nothing should be certified under penalty of perjury until they are answered. Most IRS letters do not close a route; an examination does.

In every route the signatures and the filing stay with you or the accountant you choose; nothing is filed on your behalf. Written questions to hello@atamatax.com reach a person — we aim to reply within one business day. Who does what in each route.

Your next step · free

Do you have to file — and what?

Thirteen questions; a form-by-form profile of which US filings your situation likely needs, which it does not, and what would settle the rest. Free, no account.