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Expatriation Exit Tax CalculatorCovered Expatriate Tests and 2026 Exclusion

What does this come to under the current IRS rules?

Covered expatriate status under the 2026 $211,000 tax test and $2 million net worth test, and tax on deemed-sale gain above $910,000.

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Your figures
Example figuresIllustrative only. Type over them with your own.
Exit tax on the deemed sale
$497,420
Section 877A mark-to-market, 2026 expatriation
Gain above the $910,000 exclusion
$2,090,000
Drawn to one scale
Exit tax on the deemed sale$497,420
Gain above the $910,000 exclusion$2,090,000
All results
MeasureResult
Exit tax on the deemed sale$497,420
Covered expatriate
Net worth test met
Yes
Gain above the $910,000 exclusion$2,090,000
How this was worked out
Work shownrecomputed as you type
Covered if average net income tax > $211,000 (2026), net worth >= $2,000,000, or no compliance certification
Taxable gain = deemed-sale gain - $910,000 (2026)
Tax = taxable gain x rate you enter

Illustrative arithmetic on the figures you enter. Check the result against your firm's methodology before relying on it.

The formulas

  • Covered if average net income tax > $211,000 (2026), net worth >= $2,000,000, or no compliance certification
  • Taxable gain = deemed-sale gain - $910,000 (2026)
  • Tax = taxable gain x rate you enter

How it works

Rev. Proc. 2025-32 sections 4.37 and 4.38 set the 2026 tax liability test at $211,000 of average annual net income tax for the five years before expatriation and the mark-to-market exclusion at $910,000. The IRS expatriation page states the net worth test of $2 million on the expatriation date and the certification test on Form 8854.

A covered expatriate is treated as selling all property at fair market value the day before expatriation. Deferred compensation, specified tax-deferred accounts and interests in nongrantor trusts follow separate rules. Exceptions for certain dual citizens from birth and some people who expatriate before age 18 1/2 are not modeled.

Illustrative figures only. Check the result against your firm's methodology before relying on it.

Common questions

Is the $2 million net worth test indexed?

No. It is a fixed statutory amount.

Which rate applies to the gain?

The gain keeps its character: long-term capital gain rates and the 3.8% NIIT for appreciated investments, ordinary rates for other items.

What is the penalty for not filing Form 8854?

$10,000, and a person who fails to certify is a covered expatriate.

Sources

Runs in your browser. The figures you type are not sent to CORAA or stored. Check the result against your firm's methodology before relying on it.

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