Who this is for
- High-net-worth clients considering expatriation
- Long-term Green Card holders
Expatriation & Renouncing
Exit tax & covered persons
Covered expatriates face a mark-to-market exit tax. We model your position before you renounce.
Overview
Why this filing matters
Covered expatriates face a mark-to-market exit tax. We model your position before you renounce.
Note — Mark-to-market exit tax rules.
What you get
- Covered-expatriate analysis
- Mark-to-market modelling
- Pre-expatriation planning
Our approach
Built for the cross-border edge cases.
Most US-UK filings fail the same way: a treaty position that wasn’t disclosed, a foreign account that slipped under FBAR thresholds, a PFIC election filed in the wrong year, a carry-forward not tracked from one preparer to the next. The cost of any single one of those is rarely catastrophic on its own — it’s the compounding over multiple filing seasons that quietly turns a clean tax life into a six-figure remediation project.
We start every engagement by looking at the edge cases first — the elections, the disclosures, the carry-forwards, the side-effects on next year’s return — and only then turn to the routine line items. The result is a filing that reads cleanly to anyone who picks it up next: another preparer, the IRS, or a successor in your own business.
- Position memo on every meaningful election, with the reasoning written down for the next return
- Carry-forwards (FTC, capital losses, PFIC basis) tracked year-on-year so nothing expires unused
- Plain-English commentary on every position taken — the kind that makes a future audit a non-event
Our process
How we handle your exit tax & covered persons
Four steps from first call to filed return. Fixed fee confirmed before any work begins.
- 01
Intake
30-minute scoping call. We confirm your situation, required filings, and send a tailored document list.
- 02
Review
We analyse your position, flag any cross-border risks, and confirm the scope and fee before any work starts.
- 03
Prepare
Draft returns and schedules are prepared with plain-English commentary on key positions for your review.
- 04
File
E-file with the IRS / FinCEN, send confirmations, and handle any follow-up notices or questions.
Pricing
Fixed fees — no surprises
Exit-tax modelling and covered-expatriate analysis: £1,800 + VAT. Multi-year pre-expatriation planning (asset timing, gifting strategy, compliance cleanup) is quoted per engagement.
FAQs
Common questions about Exit tax & covered persons
What triggers the exit tax?
Being a 'covered expatriate' on your expatriation date — based on the net worth, tax-liability, or certification tests. Avoiding covered status avoids the exit tax entirely.
Is there an exemption amount?
Yes — $866,000 of net gain (2024, indexed annually) is exempt. Exit tax applies only on the excess, taxed at long-term capital gains rates.
Can I defer the exit tax on pensions?
Pensions have special rules — they're generally not marked-to-market but instead taxed when distributions are paid, with 30% withholding for covered expatriates going forward. Treaty relief rarely reaches this.
What if I don't have cash to pay the exit tax?
You can elect to defer payment by posting adequate collateral and paying interest at the underpayment rate. Rarely optimal, but an option if you're illiquid. The election is per-asset.
Ready to get this filed?
Tell us your situation and we'll confirm scope, a fixed fee, and the documents we need — usually within one business day.