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.

◉ Expatriation & Renouncing

Exit tax & covered persons

Covered expatriates face a mark-to-market exit tax. We model your position before you renounce.

Request a fee quote ← Back to Expatriation & Renouncing

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.

◉ Who this is for

•High-net-worth clients considering expatriation
•Long-term Green Card holders

✓ What you get

✓Covered-expatriate analysis
✓Mark-to-market modelling
✓Pre-expatriation planning

At a glance

Key forms: 8854
Category: Expatriation & Renouncing
Turnaround: 2–3 weeks once documents are complete
Filed by: ACCA-qualified IRS Enrolled Agent

Our approach

The exit tax, modelled before you sign.

Renouncing US citizenship or giving up a long-held Green Card is an irreversible step with a tax test attached. Whether you are a 'covered expatriate' — and whether the exit tax bites — turns on net worth, average tax liability and five clean years of compliance, and the modelling has to happen before you file Form 8854, not after.

We run the covered-expatriate analysis first, show you where you stand against each threshold, and sequence any catch-up filings so you are compliant before expatriation rather than caught out by it.

Covered-expatriate status tested against all three thresholds up front
Exit-tax exposure on unrealised gains modelled before Form 8854 is filed
Pre-expatriation compliance sequenced so the five-year test is actually met

Wealth and estate planning documents on a desk

Our process

How we handle your filing

Four steps from first email to filed return. Fixed fee confirmed in writing before any work begins.

Intake

Send us your situation by email or the enquiry form. We come back with the questions we need answered — every source of income for the year, filing history, accounts and entities — and a tailored document list.

Review

We analyse your position, flag any cross-border risks, and confirm the scope and fixed fee in writing before any work starts.

Prepare

Draft returns and schedules are prepared with plain-English commentary on key positions for your review.

File

You sign electronically; we e-file with the IRS / FinCEN and send you the acceptance confirmations for your records.

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.

Prices are indicative starting points and exclude UK VAT, which applies to UK-resident clients only. We quote in writing once we have confirmed every source of income and your filing history for the years involved.

Request fee quote See full pricing →

FAQs