When do I file Form 8854?

With your final-year tax return — typically a dual-status 1040/1040NR covering the period before and after expatriation. Due by the normal filing deadline of the year after expatriation.

Am I a 'covered expatriate'?

Yes if you meet any of: (1) net worth >$2M at the expatriation date; (2) 5-year average tax liability above the annual threshold (~$200k indexed); or (3) failure to certify 5 years of US tax compliance. Any one test makes you covered.

Mark-to-market on your worldwide assets as if sold the day before expatriation. Net gain above the exemption (~$866k for 2024) is taxable at capital gains rates. Pensions are valued under a different regime.

Can I avoid covered-expatriate status?

Sometimes, with years of pre-expatriation planning — asset gifting, income timing, maintaining compliance, managing net worth. Starts 3–5 years before the expatriation date ideally.

Do I lose access to my US accounts after renouncing?

Legally no, but some US banks and brokerages close expatriate accounts automatically. We coordinate with your investment advisor on banking continuity before the renunciation date.

◉ Expatriation & Renouncing

Expatriation return

The final US tax filing when you renounce US citizenship or give up long-term Green Card status.

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Short answer

Anyone who renounces US citizenship, or gives up a Green Card held in 8 of the last 15 years, must file Form 8854 with a final dual-status return. You are a 'covered expatriate' — and exposed to the exit tax — if your net worth is $2 million or more, your average tax liability exceeds the inflation-indexed threshold, or you cannot certify five years of tax compliance.

Overview

Why this filing matters

The final US tax filing when you renounce US citizenship or give up long-term Green Card status.

Note — Renouncing US citizenship.

◉ Who this is for

•Clients renouncing US citizenship
•Long-term Green Card holders expatriating

✓ What you get

✓Form 8854 preparation
✓Final-year 1040 / 1040-dual-status return
✓Coverage of covered-expatriate rules

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

Expatriation return package: from £2,500 + VAT — covers the final 1040/1040NR and Form 8854. Pre-expatriation planning, exit-tax modelling, and multi-year strategy are quoted separately.

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.

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FAQs

Common questions

Sources

Rules, thresholds and penalties are as published by the IRS and FinCEN at the time of our last review (2026-09-08); always check the current instructions for the year you are filing.

Related services

Others in Expatriation & Renouncing

Exit tax & covered persons

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

Learn more →

Who this is for

Situations where this filing usually applies

Guides from our team on this topic

Ready to get this filed?

Tell us your situation and we’ll reply by email within 2 working days with our questions, then a written scope, fixed fee and document list.

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